InRevenueRuling55-342,ATF's predecessoragencyinterpretedthemeaningoftheterms "manufacturer" and "dealer" for the purpose of firearms licensing under the Federal FirearmsAct,theprecursorstatutetotheGCA. Itwasdeterminedthatalicenseddealer could assemblefirearms from componentparts on an individual basis, but could not engagein the businessof assemblingfirearms from componentparts in quantity lots for purposesof sale or distribution without a manufacturer's license. Since then, ATF has similarly and consistently interpreted the term "manufacturer" under the GCA to mean any personwho engagesin the businessof making firearms, by casting, assembly,alteration, or otherwise, for the purpose of sale or distribution.
Performing a cosmetic process or activity, such as camouflaging, that primarily adds to or changesthe appearanceor decoration of a firearm is not manufacturing. Unlike manufacturing processesthat primarily enhancea firearm's durability, camouflaging is primarily cosmetic. Likewise, external engravings are cosmetic in nature and primarily affect only the appearanceof a firearm.
Held, any personwho engagesin an activity or processthat primarily addsto or changesa firearm's appearanceby camouflaging the firearm by painting, dipping, or applying tape does not need to be licensed as a manufacturer under the Gun Control Act.
Heldfurther, any personwho engagesin an activity or processthat primarily addsto or changesa firearm's appearanceby engraving the external surface of the firearm does not need to be licensed as a manufacturer under the Gun Control Act.
Heldfurther, anypersonwhoislicensedasadealer,whichincludesagunsmith,and who camouflagesor engravesfireanns asdescribed in this ruling does not needto be licensed as a manufacturer under the Gun Control Act.
Heldfurther, anypersonwhoisengagedinthebusinessofcamouflagingor