ATF: Accessories Submitted for GCA or NFA Approval Must Be Submitted With a Firearm
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The ATF’s Firearms Technology Industry Services Branch just sent out the following notification via email:

Effective Immediately:

The Firearms Technology Industry Services Branch (FTISB) classifies firearms as defined by the Gun Control Act (GCA) and National Firearms Act (NFA) based on the configuration and the design features of the firearm as submitted by members of the industry.

Effective immediately, any requests for a determination on how an accessory affects the classification of a firearm under the GCA or NFA must include a firearm with the accessory already installed. Except in cases of conditional import determinations, FTISB will not issue a determination on an accessory unless it is attached to the submitted firearm.

If you have previously submitted a sample accessory for classification, FTISB will be returning your sample without classification. FTISB will contact you in the near future with further instructions to facilitate the return of your sample.

Check it out here. In past cases involving the ATF and firearms submitted that have been determined to be NFA items the ATF has returned them when the person/company involved possesses the correct SOT. In instances where the correct SOT has not been in place those items have not been returned.

One cannot help but wonder whether or not this has anything to do with upcoming regulatory actions.

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  1. It’s for the Trump bump stock ban. As a bonus if you send something in and it’s deemed a machine gun or SBR they can arrest and get you convicted and send you to the gulag for violating unconstitutional “law”.

    • So if I make a Slide-ish Fire stock and attach it to a Ruger SP101 and it comes back with a smiley sticker from the ATF, is all well?

      But then what if some FUDD attaches my product to a black rifle? Does anything change? Will the firearm or firearm accessory only hold its ATF designation when attached to the exact same firearm as when submitted to the ATF?

      This is a bottomless can of worms.

      • Shoe lace + key ring = shoe lace + key ring
        Shoe lace + key ring + mini14 = machine gun

        I think the idea is anything thats pulling the trigger other than you finger is no bueno when its attached to the gun. I cant think of many devices that will port over from a revolver to a rifle other than a crank fire device er something. Are there any specifics to you example?

        • To all re: the finger thing…. I know. Thats my point. I cant think of anything that will make a revolver go the same way a semi auto will go. Not even a bump stock or belt loop. Only thing I can think of is a trigger crank or some other solenoid firing device (which again ATF says is verboten).

          Otherwise, when not attached to the gun, a solenoid is a solenoid, a crank is a crank, a bump stock is bump stock, and shoe lace is a shoe lace…… unless its attached to a gun, then it becomes a machinegun, I guess?

      • yep, thats exactly what they want. make it so convoluted that no one can understand it and most people will just give up.

  2. If a “bump stock” is determined to be a “machine gun” by the ATF, subject to registration, Outright bans are unconstitutional–a mechanism would have to be in place to allow for all currently-owned “bump stocks” to be “registered”, such as what was done during the 1968 “amnesty” or the 1986 “reclassification” of the “Street-Sweeper shotgun”. Any registered “bump stock” owner could then modify the weapon that it is attached to, such as a SBR or further…interesting possibilities.

    • Hm.

      I am not at all conversant on the details- class 3 hardware is not legal in my state unless you’re grandfathered- but once a gun is in the registry as a ‘machine gun’, would it matter if the mechanical detail was a bump-stock, or a DIAS?

    • You are wrong. Please stop repeating falsehoods. None of those other items you describe were declared machineguns, and the Hughes Amendment specifically bars the government from adding new entries to the machinegun registry. The stocks are being declared contraband, they do not have to accommodate current owners in any capacity. It might be a complete betrayal and outrage, but it is fully within the legal boundaries of our federal leviathan at this time, with lots of legal and practical precedent. No one gets a voucher for their bath-salts when Uncle Same declares them drugs, no one will get a registered machine gun out of this bump stock mess. No one will be compensated when AR15s with semi-auto disconnectors are judged to be machine guns per the regulatory Pandora’s box Trump has opened on us.

      • While I agree with your assessment that they will be deemed contraband.

        Your bathsalts analogy is 100% WRONG.

        Bathsalts makers didn’t submit copies to the relevant regulatory agencies asking for an opinion on their legality.

        Lets not forget that Slidefire submitted stocks to the ATF for an opinion BEFORE they started commercial production. The ATF approved them. IN WRITING.

        This is the real problem with this upcoming reg. It has nothing to do with firearms per se. It has EVERYTHING to do with an ex-post facto prohibition on an item that was explicitly approved by the same government entity that is now about to outlaw it.

        • Yeah it’s a real dick move by the feds but there is no ex post facto going on here. The agency that for some reason we’ve all agreed on as the arbitrator of accessories gave them the go ahead for a good run. Now our federal government is going to declare them contraband. You won’t be arrested for having possessed one while they were legal so ex post facto has you covered on that, but you can bet your ass that’s an easy add on charge when they’re illegal.

  3. This is all about casting shade & worry on to bump stocks, braces, foregrips, triggers, basically everything that isn’t getting a “firearm or no?” examination.

    The ATF finding will apply ONLY to that particular accessory (as it was before) on that particular firearm configuration; that’s what’s new. So now when the next hot brace or bump-fire gizmo or NFA workaround/ATF-face-slap comes out, there will be no guarantee it’s legally acceptable for anything BUT the gun it was submitted with.

    So anyone not shooting the most common M4gery variant out there is likely to be left wondering and without explicit legal protection. Enforced vagueness for maximum ‘discretion’ on the part of the Bureau.

    On the one hand, this can be a step toward the ATF giving up on these issues; they’re basically making it impractical to get determinations going forward which could mean they no longer care. On the other hand, all it takes is a president to sign some boneheaded executive memorandum stating everything that has not been explicitly approved shall be prosecuted, and it’s game on. Seeing as this is Trump we’re talking about, it’s not the former, and most likely some gambit to make it legally risky to develop, sell, or use popular firearm accessories that ‘skirt’ (aka “completely and fully comply with the law in good faith”) the NFA.

    I’m starting to think there really is a Donald Trump Presidential Second Amendment Coalition concocting his firearms policy goals…just not the kind we were expecting.

  4. Maybe…

    But it could be read…

    If you wish for the ATF to review an item that is an accessory, please provide the firearm it is intended to be used on so the ATF does not have to procure the firearm in order to fully examine the item in questions forma and function.
    I’d like to imagine the ATF doesn’t keep one of every firearm produced just in case they need to match something to it, not to mention they would need every type of stock and barrel length as well as magazine type, etc…. or they would have to acquire each.

    Sometimes not everything is as shady as it seems.
    Sometimes it is.

    In my experience with the feds, they’re probably just pushing the work load onto the maker so its less work for them.

    • “I’d like to imagine the ATF doesn’t keep one of every firearm produced”

      No, they actually do.

      It’s called the National Firearms Reference Vault, and it’s quite real. Interesting criminal guns, too, one-offs and the like, in addition to pretty much every single variant of every single military gun from every military/police agency the world over since the 1940s, more or less. Oh, and examples of nearly every commercial firearm that’s been produced in the USA or imported here.

      Yes, really. There are some very impressive pictures available, too…

    • Your logic sounds good.
      Problem is, though, if what you say is right (aside from the “not having one of each” thing which is just wrong), then only that one combination of gun/accessory could be considered legal. This would mean that the accessory maker would need to ship one of each type of firearm to the BATFE{ARBF) with the accessory installed, which would be absurd.
      There’s something else afoot here, possibly as benign as the BATFE(ARBF) not wanting to put itself in the position of incorrectly installing the accessory, and granting/not granting permission based on that faulty installation.

  5. What constitutes an accessory that must be submitted for approval?

    Flip-up sights?
    A new scope model or even just the rings?
    Mountable flashlight?
    Flash hider or break?

    I can see triggers (and bump stocks), to check that they can’t be easily made full auto. If there is some criteria for requiring approval how do they define it? Or is anything that’s designed to clip, screw, or otherwise mount on or modify a firearm included?

  6. Shady it is !! If it walks & quacks like a duck , it ain’t a squirrel. Speaking of squirrel’s , I think it’s time to start storing / stocking up on every part needed to fix , build , and maintain any future firearm one may need. I fear it is only a matter of time ‘ very short ‘ window of opportunity we may have. The next federal law that pops up out of nowhere , could very well be internet sale of any thing gun related. It sickens me to think of what these commie loving , gun grabbing , left-wing pos are doing , trying to do to our country.

    • It’s already in the pipe, (parts kit ban) if you can’t fix or maintain your firearm, won’t work if its broke and illegal to buy/order parts, even magazines.
      Maybe the only workaround legally is to send it to a manufacturer for repair because it will be a crime to work on your gun.
      Then to get it back FFL only background check, license to own mental health evaluation/health record review, social media review, and training class cert.
      That IS our future, especially here in the Democratic socialist utopia that is Washington state.

    • Yup. This administration has shown that they are no protection against the anti-2A crowd. And it will only get worse as Democrats take the house.

      As you said: stock up. Any future purchase you were pondering, get it now.

  7. So how do they evaluate if an item turns something into a firearm (like a cartridge conversion cylinder for a cap and ball revolver does)?

    • They’ll form an ad hoc committee to make shit up. Or change the meaning/definition of words.
      Like what happened to bump stocks or the definition of semi automatic assault rifle (ruger 10-22) and ALL SEMI AUTO firearms in WA state.

  8. The good news: You can all stop worrying about Democrats infringing on your 2A rights.

    The bad news: Because Republicans will do it for them.

  9. Is Paddock really dead? Or is he looking for his lost shaker of salt down in Margarita ville? I would be very angry if I purchased a government approved item and then have it banned by that government, with my only choice’s ,give it back or go to jail or register it. Borderline coercion.

    • borderline force? Not so sure about that. As with all govt overreach it carries credible and possible excessive level of force especially as in this case the person has done nothing more wrong than possess an item that was previously legal when they bought it and has now been made illegal. If an action causes no harm to someone else then the way our justice systems (in both the US and australia and taken from the common law fought for for several centuries before the founding of either of our nations) are supposed to work is that there is then no crime. This means that 99% of statutes written including most of the road rules, gun laws etc etc are against the common law both our nations were founded upon especially when juries are not told they have the Right and Duty to nullify laws they feel to be unjust

  10. This the reason my new device is being SBR-ed even though it comes with a brace. I look for the “brace letter” to go the way of the “bump stock letter” and dodo bird. Just my .02

    Also would not be surprised the $200.00 tax stamp ends up “being adjusted for inflation”, given the current lib politics gaining headwinds.

  11. My guess is that the NRA, GOA, SAF, … challenge this immediately. If you were to take this policy to the logical extreme then and accessory submitted with say a LMT lower would not be approved on say a RRA lower. Even worse, it may make it questionably legal to build your own AR or other rifle as you could not mix uppers, lowers, triggers, stocks, barrels, etc. that were not previously approved together. My guess is that the ATF itself may not have thought this through. Having said this, it is a good thing that this is happening now while we have a friendly-ish administration so that this can be put to bed in a responsible manner. If the Dems had figured this out in 3 years when in all probability they will control the executive and both houses of Congress, it could have been a disaster.

  12. Michael Curtis and the rest of FTISB at BATFE would reflect a great honor upon themselves and the United States Constitution to amend their testing procedures to begin by placing the technology in their own mouths.

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