I have machined a few of my handgun slides to accept a micro red dot. Currently there is a decent business available for machinists with the equipment to do the job properly. My question is. Can I accept slide only (no frame or receiver or other serialized parts) into my shop to CNC mill the slide for rmr? Or does this constitute being in the "gun business"?  I have sent an e-mail to the ATF with this very same question but, I dont know when I will hear back from them. As far as I can read from any of the ATF frequently asked Q&A I can do such business. I could also for example make parts such as charging handles, handguards etc.. However, I dont want to be on the wrong side of the laws. I will not take any answer as an offer of legal advice. Merely asking the question to know if I should proceed with paying someone for a official interpretation of the law.

I believe that you need one. I'll look it up if Ty doesn't respond first.

 

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Also, don't forget the $2250 ITAR fee that you will have to pay.

Why would I have to pay ITAR? No plans to manufacture guns.

I just read yesterday on Calguns if the owner is present or you don't keep receiver you don't need FFL. Not positive if that is 100% correct but many there thought it was. Also unsure if NJ has their own laws.

 

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Why would I have to pay ITAR? No plans to manufacture guns.

Google "ITAR gunsmith fee"

Several guys in the state that do cerakoting/gunkote seem to have FFLs now or be under another businesses FFL.  Even spraying slides and stocks was considered to be gunsmithing.  Not sure if it was state or atf that took issue with how they were doing business.

https://www.atf.gov/firearms/docs/ruling/2009-1-firearms-manufacturing-activities-camouflaging-or-engraving-firearms/download

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A friend of mine looked into this and he was told he would need the type of licensing for a gunsmith and a lot of insurance in case his parts fail etc..

I read the link to ATF as well as the other comments. I agree that anyone modifying a firearm in any way needs an FFL. My argument is that I am never touching a firearm. The slide or upper or barrel is not a firearm. The only part that is a firearm is the part that carries a serial number frame, receiver, lower. To my knowledge those parts are not regulated in any way.

Guys that cerakote or engrave generally take possession of a firearm frame/receiver.

I read the link to ATF as well as the other comments. I agree that anyone modifying a firearm in any way needs an FFL. My argument is that I am never touching a firearm. The slide or upper or barrel is not a firearm. The only part that is a firearm is the part that carries a serial number frame, receiver, lower. To my knowledge those parts are not regulated in any way.

Guys that cerakote or engrave generally take possession of a firearm frame/receiver.

I think you're right. No serial number possessed, no license needed.

 

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So they were correct about making changes to parts other than the receiver overnight but what about making changes to the receiver while the owner is present?

 

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So they were correct about making changes to parts other than the receiver overnight but what about making changes to the receiver while the owner is present?

 

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Its my understanding (for what its worth) that making changes to a receiver/frame of any kind constitutes gunsmithing. The receiver/frame is the firearm because its the only part that caries a serial number. However, manufacturing parts (other than the receiver) such as barrels, uppers, triggers etc... may be subject to ITAR. I do hope that ATF replies to my question soon. 

Its my understanding (for what its worth) that making changes to a receiver/frame of any kind constitutes gunsmithing. The receiver/frame is the firearm because its the only part that caries a serial number. However, manufacturing parts (other than the receiver) such as barrels, uppers, triggers etc... may be subject to ITAR.

So maybe it is if you don't charge for making the changes and the owner is present? I remember this coming up a couple years ago involving people helping each other out with Saiga conversions, and there were some people charging for it. I forget what the conclusion was then, but I guess now it is a no go without a FFL.

 

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So maybe it is if you don't charge for making the changes and the owner is present? I remember this coming up a couple years ago involving people helping each other out with Saiga conversions, and there were some people charging for it. I forget what the conclusion was then, but I guess now it is a no go without a FFL.

 

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There are plenty of loopholes and gray areas. You can help a friend make upgrades or changes as long as no one is compensated for their time/work. As a machine shop owner I would not. Not because its illegal, but it "looks suspicious".

 I personally dont want to find myself in a gray area that requires a defense.

There are plenty of loopholes and gray areas. You can help a friend make upgrades or changes as long as no one is compensated for their time/work. As a machine shop owner I would not. Not because its illegal, but it "looks suspicious".

I personally dont want to find myself in a gray area that requires a defense.

If you were to get an FFL do you think you are capable of making a Stgw57 Receiver? If so we need to talk if you decide to get a FFL.

 

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IMO, any cosmetic change to a "firearm", one needs to be a dealer. Any modifications, one needs to be a manufacturer.

 

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IMO, any cosmetic change to a "firearm", one needs to be a dealer. Any modifications, one needs to be a manufacturer.

 

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I agree 100%. But, this isnt a firearm. A firearm is a receiver/frame that carries a serial number. If I buy a 1911 frame from a FFL we have to NICS etc.. If I buy a 1911 slide from anyone then nothing is required. Effectively the same as buying a wrench at sears.

If you were to get an FFL do you think you are capable of making a Stgw57 Receiver? If so we need to talk if you decide to get a FFL.

 

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The short reply to this is YES, as a full service machine shop CAD/CAM/CNC engineering, welding, manual machining there really isnt any part that we cant make. The devil is in the cost/time. That receiver may only have $25 in raw material. But due to engineering, machine setup, sub contracting the EDM if needed there may be 200 hours to make one, might only be 210 hours to make 50. So, the first one $20025.00 and lot of 50pcs $425.00 each. These are not actual numbers, just an example. Hope you get the idea. Whenever I look at guns I can believe they are able to sell them at the price they do and make money. Beretta gets about $200 for a 92, add wholesale markup, distributor markup, then retail markup (which is surprisingly small) and you end up paying $550. Thats really a subject for another thread.

If you could make receivers for a Stgw57 for under $500 you would sell 1,000 in minutes. If you decide to do it please let me know.

 

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I agree 100%. But, this isnt a firearm. A firearm is a receiver/frame that carries a serial number....

See post 12.

 

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Since PK90 is on this thread I have a question that ties in. How hard or easy is it to convert Argentine FN-49 mags to 15 rounds?

 

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Maybe I will get lucky and new federal government will rule NJ laws invalid.

 

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Please notice that in the following regs there is no stipulation that if it is not a serialized part you're exempt. They reference threading barrels, cutting chambers etc - these are individual, non-serialized parts - just as a slide would be. Not sure if ATF is now the only arbiter of what constitutes being in the business of gunsmithing. Here's the article...

 

http://www.accurateshooter.com/technical-articles/fed-itar-registration-for-gunsmiths/

 

Adios,

 

Pizza Bob

Please notice that in the following regs there is no stipulation that if it is not a serialized part you're exempt. They reference threading barrels, cutting chambers etc - these are individual, non-serialized parts - just as a slide would be. Not sure if ATF is now the only arbiter of what constitutes being in the business of gunsmithing. Here's the article...

 

http://www.accurateshooter.com/technical-articles/fed-itar-registration-for-gunsmiths/

 

Adios,

 

Pizza Bob

That is a scary article. It wasnt clear to me. Has it been passed and become active or was it merely a proposal? What I want to do is the equivalent of mounting a scope. Every gunshop I know of drills and taps rifles for scope mounts. That defines them as "in the business" of gunsmithing. As I read the article that subjects them to ITAR ruling. I wonder how many know about this.

Has it been passed and become active or was it merely a proposal?

In effect now