Here’s Why Pennsylvania FFLs Should Comply With The New ‘80% Receiver’ Rules

Source: Pennsylvania State Police

As expected, the Pennsylvania State Police have informed Federal Firearm Licencees in that state that they must begin performing background checks for the sales of “Partially-Manufactured Frame(s) or Receivers” (PMFR) and record that transaction on a new form. As Pennsylvania attorney Joshua Prince notes, this is problematical because the letter doesn’t really specify just what a PMFR is.

For that, we go to the original opinion letter from Attorney General Shapiro. He has established that everything is a PMFR. If you can turn something into a gun with $65,000 in thirteen hours, it’s a gun.

In that case, I think it’s very important that every Keystone State FFL comply with this completely, taking AG Shapiro at his own literal word.

If an FFL sells anything, he should fill out the application and make the background check call. Individually list every item a customer wants, be it a bottle of solvent (plastic bottles can be melted down and molded into a receiver), a block of wood (stock), a metal gun case (sheet metal can be formed and cut into a frame), or whatever.

Use your imagination. Overload their switchboard and smother them in paperwork. Better safe than sorry, and the the PSP will come down on you later if you miss something.

If they later insist you don’t need to do this for item X, get it in writing, over a real signature. Document everything.

Until then, make them work for their new regulation.


  1. avatar uncommon_sense says:

    Without any limitations of time or money, a resourceful person could use anything made of wood, plastic, nylon, composite, resin, or metal to manufacture a firearm. Thus, everything that a federal firearm licensee in Pennsylvania sells could become a firearm.

    1. avatar LarryinTX says:

      Why not just mail order, if the feds don’t see it as a gun?

      1. avatar anonymous says:

        It’s not a “Partially-Manufactured Frame(s) or Receivers” (PMFR)
        It’s a paperweight.

        Is a 0% lower a partially manufactured frame or receiver? Is a 10% lower a partially manufactured frame or receiver? Why not?

        1. avatar DavidT says:

          A large enough block of virtually anything can be made into a receiver, with tools, time and skill. The point is to beat them with their own rules, overload the system so it breaks down. When they can’t process any requests then sue them for everything related to denying your rights that you can think of. A genius tactic, one that has been used many times by the left. It’s time to start playing by their rules to level the playing field.

    2. avatar Blue says:

      Dumbest idea ever.

      First of all, customers aren’t going to pay the fee for simply buying solvent. They will go online and buy it without the hassle and extra expense.

    3. avatar Southern Cross says:

      It’s what happens when regulations are made in haste and ignorance of the topic. It either results in lots of loopholes or something so broad it encompasses almost everything.

  2. avatar David deplorable says:

    Olenski’s rules for radicals. Make them live up to their own rules.

    And yes talk to text sucks

    1. avatar Unlicensed Bozo says:

      Spelling correction and link to rules . (Alinsky)

      1. avatar Geoff "I'm getting too old for this shit" PR says:

        You can train that ‘voice to text’ program, you know.

        Someone I know was very pleased when he trained his to type “six-pack” (with the ‘dash’)…

  3. avatar Fred B says:

    Actually I know of a build from melted aluminum pop cans. Therefore…..

    1. avatar Jeff the Griz says:

      Time to start selling 79% lowers.

    2. avatar EWTHeckman says:

      Yep. Grocery stores and hardware stores will also have to comply.

    3. avatar Frank says:

      Ive seen videos of brass lowers and one guy used a shovel to make an ak

  4. avatar Dan says:

    A new battlecry goes out “I will over-comply!”

    1. avatar Mercury says:

      The Germans call this tactic “papierkrieg” (lit. paper-war.) While it’s usually the bureaucratic stall tactic we all face on a regular basis, there are numerous cases of it being used in exactly this way, to turn a law which is so overly broad as to make everything a potential offense into a resource drain by documenting every potential offense. As silly as this article sounds, history does bear out the notion that you can make yourself so annoying to a higher echelon of a bureaucracy that they crack down on the misdeeds of the lower onc which is preying on you.

      Though technically, since the law to which this applies is a matter of strict liability (i.e. no intent to commit a crime necessary for it to be an offense) this would be complying with exactly the spirit of the law, as well as the letter.

      1. Good idea. In the early stages of the Civil Rights movement the NAACP was suing to make what was separate truely equal, which was expensive.

  5. avatar I Haz A Question says:

    I get that the author wants to be facetious and make life difficult for the PSP, but I won’t buy anything from any FFL (whether in PA or in my home state of CA) if that FFL involves a legally unnecessary call containing MY personal information. The author and his jolly band of rebellious FFLs can play their Jedi mind tricks with cops without using my info, thankyouverymuch.

    Besides, it’s my understanding that a Police organization cannot makes changes to State law by diktat. That is, unless the PA Legislature somehow underwent the moronic step of abrogating their rightful authority to the PSP.

    Regardless, there’s a reason why I built my own various guns from 80% frames, and it does NOT involve wanting to voluntarily hand over information to any police.

    1. avatar DH2 says:

      In actuality there is nothing facetious at all about the notion of malicious compliance. It is the precursor to offensive compliance. If people abide by the stupid law and actually file the paper work on every single item that could possibly be a PMFR, that lays the ground work for suing companies, government organs, and the state itself into compliance. Not only to you drain state resources in complying with their stupid law, but it forces them to go on the defensive to respond to litigation. It also provides cover for any LEOs who want to demonstrate the stupidity of the law to arrest political figures who support the measure and are in violation of it. To deny persecution of those individuals forces the legal system to advocate for ‘rule for me rule for thee’ which tends to piss people off even if they don’t have a dog in the gun fight.

    2. avatar Goddard, Jr says:

      I was experimenting with making my own rocket fuel from commonly found ingredients at the drug store in my pre-teens. I did not have access to a lot of ingredients, but did eventually come up with a way to start generating Saturn V fuel, as in the moon rocket. Came up with some Other novel fuels as well, but also made a lot of black powder incidentally. Had I wanted to make gunpowder, I would have, and with much less effort, made a lot of smokeless powder.

      1. avatar I Haz A Question says:

        Your entertaining but implausible story about recreating fuel that powered the Saturn V rocket (which, by the way, was the forced combination of massive amounts of liquid oxygen and liquid nitrogen) wouldn’t have anything to do with your choice of username, would it?

      2. avatar Whoopie says:

        The first stage of the Saturn V used RP-2 (refined kerosene) and LOX. The second and third stages used Liquid hydrogen and LOX. So you were wasting your time trying to make any of those using drugstore chemistry.

    3. avatar Mastro says:

      They shouldn’t put their customers in a bad position- they should take volunteers who are willing to do the form. Does it cost anything? If so- the FFL should set aside $100 or so to pay for them.

      If its free- do as many as time allows. If there are 1000 or so FFL’s- a mere 10-30 each would really swamp the state system.

  6. avatar DanC says:

    It seems to me that convenience stores, grocery stores, and hardware stores should be required to have an FFL. Soda cans, with the correct equipment, can be reformed into the dreaded AR lower receiver. Common chemicals (ammonia cleaners for example) that are found in such stores can be used to make gun powder and primers. Copper scrubbing pads can be re-manufactured into bullets. The list is endless. We will never be safe until all manor of shackles bind us into total subservience to the ruling class.

    1. avatar GS650G says:

      Those tire weights on my rims better be reported.

      1. avatar Mark N. says:

        Those are made of steel these days in most if not all states, no longer lead. Tire shops hate them.

  7. avatar Timothy Toroian says:

    Does that include billets of 4140?

    1. avatar Mercury says:

      Obviously. The issue here is that $65K and 13 hours is enough time and money to turn just about anything into billet or barstock and then machine into a reciever. Aluminum cans, plastic bottles, sawdust and epoxy… they very literally made everything a firearm and will simply prosecute selectively. Thus the call to hoist them by their own petard and flood them with the very paperwork they asked for.

  8. avatar GS650G says:

    Home depot and lowes better get their FFL license applications in.

  9. avatar Vlad Crappes says:

    I’m sure FFLs will be lining up to do all thst extra paperwork.

  10. avatar Sam I Am says:

    “…smother them in paperwork.”

    This is the technique the feds use when they don’t want to do something they don’t like: over-comply, choke the system, make the legislators take the heat for the log jam.

  11. avatar Andrew Lias says:

    You guys better start calling in your fence posts. They look an AWFULLY lot like STEN receivers I’ve seen in the past.

  12. avatar GS650G says:

    This Makita electric drill has a pistol grip on it. I bet I could turn it into a Glock with enough time and money.
    It already has a serial number so that simplifies registration.

  13. avatar The Crook says:

    Could the keyboard I’m typing on be turned into a Glock frame? Asking for a friend.

  14. avatar Marc Peters says:

    I love it!

  15. avatar Cloudbuster says:

    Since you don’t have to have an FFL to sell things that are not a firearm, how are they going to enforce this on people who sell pipes, bar stock and, oh, 80% lowers without an FFL?

    Should people turn their local Lowe’s or Home Depot in to the government?

    1. avatar Stuck in NJ says:

      Dick’s Sporting Goods is fair game. Turn in the dicks at Dick’s for not running a background check on every tennis racket, because the tennis racket’s handle could be carved into gun parts.

  16. avatar possum and the Coons of Doom says:

    Coil, I bet I can get a couple pistols made out of my bicycle,,. ,,,Well I’ll be damned Walmarts selling pistol parts

  17. avatar Mike says:

    Ummmm….. does this mean that Brownells or any of the various resellers of these things have to do this for PA purchasers? I buy mine online. No muss no fuss, none of any governments god damned business!!!!!

  18. avatar GomeznSA says:

    While the concept of burying the bureaucrats in paperwork – to show them just how ridiculous the ‘law’ is – is commendable on its face, there is a potential danger should the bureaucrats decide to go full bureaucrat, they could decide that they will go into full blown over enforcement mode. Sure, they can’t actually arrest everybody but they certainly can use a variety of fines and any other penalties they can think of in order to make life miserable for Law Abiding Citizens.
    Come to think of it, that sounds suspiciously like what the dems are planning to do in Virginia…….if they turn everyone into a prohibited person then their “gun crime/violence” problem goes away.

  19. avatar enuf says:

    There are some excellent YouTube’s of a guy who melts down aluminum cans, casts a rough receiver shape using sand casting and machines an AR lower in his home machine shop. Very cool work, real craftsmanship.

    The one he did with collected range brass? Just beautiful!

  20. avatar Stuck in the People's Republic of New Jersey says:

    Be careful what you wish for. This tactic will backfire.
    I know from experience, because I live in the People’s Republic of New Jersey.
    During the height of the Obama-gun-rush (I think it was 2012), New Jersey’s background check system got so backlogged that instead of taking minutes or hours, the state’s “instant background check” took about six weeks! Yes, over a month for each “instant” background check. This led to chaos and confusion, because New Jersey also has a “one handgun a month” limit, plus a 90-day expiration date on each “NJ permit to purchase a handgun” (PPHG), so there was confusion about whether the one-month period was one month from when you fill out the background check, or a month from when you actually pick up the gun, which could be six weeks later! Naturally, the state of New Jersey interpreted the one-gun-a-month rule in the strictest possible way, so if you had filled out a background check within the past 30 days, even if you were still waiting for the gun you ordered, you could not order a new one, so your 90-day permit to buy a second gun could expire while you’re waiting for the results of the first background check.

    Later, we found out through the grapevine that the six-week backlog on NJ background checks was due to a DELIBERATE slowdown-strike by anti-gun bureaucrats and politicians trying to make it even harder for law-abiding citizens to purchase a gun in NJ. The government’s anti-gun slowdown-strike finally ended after the Boston Marathon bombing, when someone in Trenton (the state capitol) FINALLY realized that guns can save lives during a terrorist attack.

    But my point is, be careful what you wish for.

    1. avatar GomeznSA says:

      Stuck – Carolyn Bown was unavailable to comment on your post……………………..;-(

    2. avatar Sam I Am says:

      “Be careful what you wish for. This tactic will backfire.”

      In the years of civil disobedience regarding segregation and discrimination, the purpose of getting arrested for being disobedient was not to get arrested. The purpose of getting arrested was to gain wider sympathy for the resistance. The means of getting wider publicity and sympathy was to get enough people arrested enough times that the system was overwhelmed, and the power structure responded in ways completely disproportionate to the protests. That over-reaction was then used to gain the support of people who otherwise were either opposed to the resistance, or neutral.

      In the case you describe, and the current instance, the purpose of jamming the system is the same. In the current circumstance, the resistance can jam the system until just before the power structure nears resolution of the backlog, then jam the system again. Or even allow an uncertain duration of breathing space, then jam the system again. The idea is to provoke a response from the power structure that offends people who otherwise are opposed to the resistance, or neutral.

      The impacts of jamming the system would go far beyond the applications for purchase permission.

  21. avatar T says:

    I think you are missing the point. The idea is to back log and IGNORE these checks causing people not to buy them. You are playing right into their hands. Wrong move.

    1. avatar UpInArms says:

      I agree. Once the system is jammed up with a lot of irrelevant paperwork, the bureaucrats will just let it go. Don’t lose sight of their ultimate goal — to make it as difficult as possible for us to get firearms. And if we’re the ones jamming up the system, all well and good. They’ve got us doing the heavy lifting for them.

    2. avatar Tom in PA says:

      There may be the potential to gain standing for legal action without much personal risk. I would be interested to hear what the attorneys here think.

  22. avatar Hippi says:

    cool I can buy a Mercedes with a trunk full of lowers and be ok then?

  23. avatar Michael says:

    I made this point over the weekend. I want to get the sticks from my backyard maple tree deemed a firearm so I can hand them over, with the paperwork, at the next gun buyback. That tree can hook me up with gift cards.

  24. avatar Jim Bullock says:

    In Australia it’s a workforce tactic called “work to rule.”

    The strategy of burying the system into collapse is called “Cloward-Piven”, named for the two progressive academic activists (but I repeat myself) who put it forward as a mechanism to crash federal welfare and support programs to usher in the grand collectivization of everything.

  25. avatar Bierce Ambrose says:

    If they’re denyhing a civil right through delay, isn’t that actionable? You don’t have to win; just extract a price.

  26. avatar Jed says:

    The NYS Police have decided that the ATF defined pistol known as a “Mare’s Leg” is a short barreled rifle and therefor illegal in New York. On a more relevant note a lower receiver of any configuration (80% to complete) does not meet the ATF definition of a firearm. Several court cases have turned on this bit of trivia

  27. avatar FUPA says:

    Who the hell is this Shapiro bastard AG get off making this decision?

  28. avatar Don from CT says:

    This was my attitude when CT published new AW bans post Newtown. The new law said that anything that could be used to turn a compliant firearm into an AW was an AW.

    So since pistol grips were an evil feature, I registered all my pistol grips. I also registered every lower parts kit I had. I also had a couple of threaded barrels for handguns. A handgun with a threaded bbl is an AW.

    So I registered the barrels and the handguns. The reality is that the state already knew about these guns. So why not drown the f#$kers in paper.

  29. avatar guy says:

    Liberals are like the kid from the sixth sense hiding under a blanket because everything they see is a potential firearm.

  30. avatar Hannibal says:

    I’m not sure a bunch of customers are willing to go along with this plan. Not to mention FFLs are supposedly running a business and this would waste about 95% of their time…

    1. avatar Eric in Oregon says:

      Yeah, this is a dumb and unrealistic idea. So far this author is batting 0.

  31. avatar BERT THE BUILDER says:

    Ha, i knew shit would happen eventually, so i bought as many as i could possibly afford..oh black friday made it even easier. This is bullshit too btw, first off. We have to pay extra to get permission for something that looks like a firearm..but isnt according to the ATF. It doesnt even make sense, compared to other thing i dont want to explain cuz then they will be next. I promise to not buy another new gun, i will search for used firearms n buy them that way. I have alot of guns presently..n solely for the purpose of knowing they are gonna take them Eventually. Well all i can say it good luck! Because us extremely law abiding Americas will push back eventually! Not threat its a fuckin promise!

  32. avatar Retro says:

    With $65kand 13 hours I can turn any solid, liquid and most gases into an AR lower. The favorite one a friend came up with was cow pies frozen with liquid nitrogen and machined into a lower.

  33. avatar R. Corrino says:

    As long as there is a fee associated with it that goes to the State, the State will not care. They will just take their sweet time checking each and every application. Suddenly, buying a bottle of Remoil takes you several weeks even if you are approved.

    California ammo checks shows the inconvenience is ALWAYS with the law abiding citizen, not the government.

    Make the State shoulder the cost of the burden without any fee or tax increase then we have another story…..but this is as likely as Trump winning the popular vote in California

  34. avatar RustyTheBoyRobot says:

    Rather than turning over more money and personal information to the government (which has already shown a propensity for totalitarianism), leverage your LEOs. Politicians seem to listen to the police more than citizens when guns are involved. Get a posse of freedom-loving people to start reporting noncompliance everywhere they see it. Lowe’s, 7-11, Walmart… It’s everywhere. Tattling is free for the informer. If LE offices start complaining of the flood of crap due to the poorly thought-out definition, they might take it up with the politicians.

  35. avatar Will Holly says:

    I think everyone overlooked a key point here. The original article/post stated that FFLs must comply with doing a background check if they sell what amounts to an 80% reciever. I get the $65k & 13 hour thing but what they’re really after is the 80% recievers. That doesn’t say non FFLs can’t sell them w/o a background check.

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