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Posted: 10/6/2025 5:03:02 PM EDT
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Although I remember talking to some other FFL's last year about this and trying to find clarity on the topic, I'm second guessing myself now. As a Type 07 who procures a stripped 'receiver' that is already marked, then logs it out to the FFL, then back in as a 'rifle' with caliber.....does that rifle have to be reported on the AFMER??? The last I recall is that since we can 'adopt' markings then there is no need to include it on AFMER. If it had been a receiver that I machined and marked myself or a 'Variance' receiver, then it would obviously be reported on AFMER. But hasn't the manufacturer of the stripped 'receiver' already reported it since they made and marked it with THEIR information, and then sold it to the distributor that I purchased it from? |
You think you're winning this game? You don't even know the God-damned rules. But don't worry, I'm gonna teach 'em to ya..
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https://www.atf.gov/firearms/qa/what-production-and-what-should-i-report-my-afmer-form My understanding is if you logged it into your manufacturing book (took a multi-cal receiver and turned it into a rifle with caliber designation), then you "manufactured" it and it goes in the report IF you entered it into commerce (sold it to someone other than a manufacturer) or exported it. |
The work speaks for itself.
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Originally Posted By alpha0815: As a Type 07 who procures a stripped 'receiver' that is already marked, then logs it out to the FFL, then back in as a 'rifle' with caliber.....does that rifle have to be reported on the AFMER??? You MFG'd a rifle that did not previously exist, so you report it. |
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Got it, thanks! For those still on hard copy / paper bound book....are you keeping a separate book for "manufacturing". Seems to me that could get difficult. Reason being... Let's say you take in stripped lower receivers that may get sold as a "receiver". That's retail. Then you / customer decides to build a complete rifle with one of those 'receivers' that are on your books. Log the receiver out to yourself, then back in as a "rifle". But it was already on your retail book...not "manufacturing". |
You think you're winning this game? You don't even know the God-damned rules. But don't worry, I'm gonna teach 'em to ya..
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Originally Posted By alpha0815: Got it, thanks! For those still on hard copy / paper bound book....are you keeping a separate book for "manufacturing". Seems to me that could get difficult. Reason being... Let's say you take in stripped lower receivers that may get sold as a "receiver". That's retail. Then you / customer decides to build a complete rifle with one of those 'receivers' that are on your books. Log the receiver out to yourself, then back in as a "rifle". But it was already on your retail book...not "manufacturing". |
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Originally Posted By HansohnBrothers: ATF guidance is to use 1 book. Don't over-think it. No, it isn't. May a licensee keep more than one "bound book" at the same time? and May a licensee maintain multiple A&D records depending on the activity conducted (e.g. A&D records for retail, gunsmithing, manufacturing, NFA, etc.)? |
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Don't let the join date fool you... here since '97
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| I didn't say it was a requirement, only guidance. |
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I haven’t seen where they say you can use 1 book. Only where they state you CAN use multiple books. I’d prefer to run 1 book for retail and manufacturing. |
You think you're winning this game? You don't even know the God-damned rules. But don't worry, I'm gonna teach 'em to ya..
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Originally Posted By alpha0815: I haven’t seen where they say you can use 1 book. Only where they state you CAN use multiple books. I’d prefer to run 1 book for retail and manufacturing. The CFR defines what the books look like. By default it is 1 book format. There can be some confusion here, as before 08/22/2022 MFGs had to use a 3 book format, and 08/22/2022 on now requires a consolidated 1 book format. So the FAQ says yes, you can use more than 1, of the 1 book consolidated format. https://www.atf.gov/rules-and-regulations/definition-frame-or-receiver/summary The records of manufacture/acquisition and disposition by manufacturers and importers must be consolidated into one book similar to dealers. The rule codifies, in part, ATF Ruling 2016-3, Consolidation of Required Records for Manufacturers and ATF Ruling 2011-1, Importers Consolidated Records, that allow licensed manufacturers and importers to consolidate their records of acquisition and disposition without obtaining a variance. I find a single book is fastest for finding stuff. YMMV. |
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