Polymer 80 frames, etc.

[Rob Boudrie]

ATF letter issued today makes ALL polymer frames "Firearms" without regard to state of completion :

View attachment 702784

Full letter heretofore annexed and incorporated by reference as if enumerated in full.

 

[Hailstorm]

So, we can sell completed frames like any other pistol. Nice.

 

[jkelly1229]

Like affective today? Or we doing a blowout sale on them

 

[Mesatchornug]

ATF letter issued today makes ALL polymer frames "Firearms" with regard to state of completion :

View attachment 702784

Full letter heretofore annexed and incorporated by reference as if enumerated in full.

"with regard" or "without regard"? Is this another "80%s are actually firearms" guidance letter?

EDIT - just started reading. I'm sure it was a typo, and you meant "without." That is, they're rescinding their previous guidance that these products were not firearms, and saying that they, in fact, are firearms. They proceed to define "Frame" and "readily" as they will from here forward be (subjectively) applied.

Further, 27 CFR 478.12(c) explains when a partially complete, disassembled, or nonfunctional frame or receiver, including a frame or receiver parts kit, is regulated as a “frame” or “receiver":

The terms ‘frame’ and ‘receiver’ shall include a partially complete, disassembled, or nonfunctional frame or receiver, including a frame or receiver parts kit, that is designed to or may readily be completed, assembled, restored, or otherwise converted to function as a frame or receiver, i.e., to house or provide a structure for the primary energized component of a handgun, breech blocking or sealing component of a projectile weapon other than a handgun, or internal sound reduction component of a firearm muffler or firearm silencer, as the case may be. The terms shall not include a forging, casting, printing, extrusion, unmachined body, or similar article that has not yet reached a stage of manufacture where it is clearly identifiable as an unfinished component part of a weapon (e.g., unformed block of metal, liquid polymer, or other raw material). When issuing a classification, the Director may consider any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials that are sold, distributed, or possessed with the item or kit, or otherwise made available by the seller or distributor of the item or kit to the purchaser or recipient of the item or kit.​

Section 478.11 defines “readily” as:

A process, action, or physical state that is fairly or reasonably efficient, quick, and easy, but not necessarily the most efficient, speediest, or easiest process, action, or physical state. With respect to the classification of firearms, factors relevant in making this determination include the following:​

(a) Time, i.e., how long it takes to finish the process;​

(b) Ease, i.e., how difficult it is to do so;​

(c) Expertise, i.e., what knowledge and skills are required;​

(d) Equipment, i.e., what tools are required;​

(e) Parts availability, i.e., whether additional parts are required, and how easily they can be obtained;​

(f) Expense, i.e., how much it costs;​

(g) Scope, i.e., the extent to which the subject of the process must be changed to finish it; and​

(h) Feasibility, i.e., whether the process would damage or destroy the subject of the process or cause it to malfunction.​

The above list of factors is a non-exhaustive list but represents factors that have been identified by federal courts as being relevant to a “readily” analysis with respect to firearms. For each and every assessment of whether any partially complete frame (in the case of a handgun) or receiver (in the case of a long gun) – whether assessed individually, or in conjunction with other items – is a “firearm” under the GCA, parties must consider the above definition, including all factors that are relevant to that assessment. This is true for all frames and receivers.

 

[Rob Boudrie]

"with regard" or "without regard"? Is this another "80%s are actually firearms" guidance letter?

Word-o fixed.

I have no details not in the letter. It also contains no indication as to the legal status of those already transferred by non-FFL businesses and without a serial number.

 

[Mesatchornug]

Word-o fixed.

I have no details not in the letter. It also contains no indication as to the legal status of those already transferred by non-FFL businesses and without a serial number.

Understood. I was asking before I started to read. Thanks for sharing the link.

 

[Broc]

So, there is no reason to buy an 80% anymore?

 

[Mesatchornug]

So, there is not reason to buy an 80% anymore?

for the moment, it would seem.

 

[DJBrad]

I would say there was a reason and that reason still strongly exists.

So, there is no reason to buy an 80% anymore?

for the moment, it would seem.

 

[DJBrad]

So, we can sell completed frames like any other pistol. Nice.

But we need to serialize them if we intend to do so since I know of no other “frame” or “firearm” that is not serialized.

 

[Rob Boudrie]

But we need to serialize them if we intend to do so

And get an 07 FFL.

 

[DJBrad]

And get an 07 FFL.

SOT should now be SOL (shit outta luck)

Not that we can’t obtain that status but most will not venture that road.

 

[paul73]

ATF letter issued today makes ALL polymer frames "Firearms" without regard to state of completion :

View attachment 702784

Full letter heretofore annexed and incorporated by reference as if enumerated in full.

i love government language.
"is issuing this open letter to assist the firearms industry and the public in understanding"

thank you for your assistance, own noble humble servants.

 

[NH_Realtor]

So, there is no reason to buy an 80% anymore?

The 79%’ers are better anyways

 

[Hailstorm]

OK, so, throw some numbers on it and you are good to go. Great!

 

[allen-1]

Hmmm. So they can’t be transferred without ffl and serialization,
which means any retail store having them in stock now has an issue.

But possession by individual isn’t affected - still legal in GA, illegal in CT for example.

 

[namedpipes]

ATF letter issued today makes ALL polymer frames "Firearms" without regard to state of completion :

View attachment 702784

Full letter heretofore annexed and incorporated by reference as if enumerated in full.

The ATF is factually incorrect, because an uncompleted lower is no more a firearm than a dish of butter is, but ok...

 

[namedpipes]

OK, so, throw some numbers on it and you are good to go. Great!

Having a serial number is not a requirement.

 

[Hailstorm]

Having a serial number is not a requirement.

Joking

 

[namedpipes]

But we need to serialize them if we intend to do so since I know of no other “frame” or “firearm” that is not serialized.

There's no such requirement in federal or Mass law for firearms that an individual completed for their own use, even if they later decide to sell it.

 

[allen-1]

There's no such requirement in federal or Mass law for firearms that an individual completed for their own use, even if they later decide to sell it.

I believe that since it’s now a “firearm” that it will have to be serialized if transferred.

and again state law comes into play. Ffl to end user requires 4473. Person to person in CT requires dps3 but person to person in GA requires no paperwork.

 

[Spartan65]

Ghost gunner 3 is already ahead of what they want to do here. They have a three piece AR lower receiver you can build from a “0%” block of aluminum.

So technology has bypassed this ruling before they could even get it out of their ass.

 

[Spartan65]

Can’t stop the signal, beep, beep.

 

[NH_Realtor]

Ghost gunner 3 is already ahead of what they want to do here. They have a three piece AR lower receiver you can build from a “0%” block of aluminum.

So technology has bypassed this ruling before they could even get it out of their ass.

It’s also all on the blockchain, so anyone can just 3D print lowers.

 

[paul73]

Ghost gunner 3 is already ahead of what they want to do here. They have a three piece AR lower receiver you can build from a “0%” block of aluminum.

So technology has bypassed this ruling before they could even get it out of their ass.

only until they will move to a next step logical outlawing all the tools next.
the crime is not in your hands - the crime is in your head. and it will be suppressed mercilessly.

 

[namedpipes]

Joking

Sorry then. It's just a shockingly common misconception.

 

[paul73]

Can’t stop the signal, beep, beep.
View attachment 702799

just curious - why do a 3 piece like that, is it for some legal reasons, or a mill limitation?

 

[Spartan65]

just curious - why do a 3 piece like that, is it for some legal reasons, or a mill limitation?

Mill limitation without going larger and needing liquid cooling.

 

[namedpipes]

I believe that since it’s now a “firearm” that it will have to be serialized if transferred.

and again state law comes into play. Ffl to end user requires 4473. Person to person in CT requires dps3 but person to person in GA requires no paperwork.

Please cite that law that a personally manufactured firearm must be serialized, ever. (Except possibly in California)

It transfers just like any other firearm.

 

[DJBrad]

There's no such requirement in federal or Mass law for firearms that an individual completed for their own use, even if they later decide to sell it.

Really? Cool.