Class 01 FFL and AR Assembly
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Old 03-16-2014, 10:58 PM   #1
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Default Class 01 FFL and AR Assembly

I've been getting a lot of people asking why I don't sell complete AR uppers. I have a Class 01 FFL and I've been scared about anything that could be construed as "manufacturing", so I've been selling individual parts, unassembled. But I have a lot of customers interested in buying complete uppers mostly.

So my question is, as a Class 01, is there anything with an AR that I can assemble and sell and not be in violation of manufacturing? Such as, can I assemble a complete upper (upper receiver, BCG, charing handle, barrel, handguard, etc)? Can I assemble a complete lower by itself (lower, LPK, buffer, and stock)? Can I do one but the other?
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Old 03-16-2014, 11:52 PM   #2
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These are the folks you REALLY need to ask-

ATF- Federal Firearms Licensing Center

244 Needy Road Martinsburg, West Virginia 24505 USA

Voice: (866) 662-2750 (Toll Free)

The folks to talk to are over in the Firearms Technical branch- the answer they give you is the one you can take to the bank. Answers from local ATF office- eh.... not so much.
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Old 03-17-2014, 12:22 AM   #3
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I'll give them a call tomorrow. Thanks for the info.


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Old 03-21-2014, 09:29 PM   #4
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I asked my ATF agent during the interview. He said as far as the ATF is concerned it is not a firearm and you don't even need a license.
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Old 03-21-2014, 10:59 PM   #5
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As long as it is the upper.
Start assembling lowers and you need another license (unless you assemble for yourself).
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Old 03-21-2014, 11:27 PM   #6
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Quote:
Originally Posted by c3shooter View Post
These are the folks you REALLY need to ask-

ATF- Federal Firearms Licensing Center

244 Needy Road Martinsburg, West Virginia 24505 USA

Voice: (866) 662-2750 (Toll Free)

The folks to talk to are over in the Firearms Technical branch- the answer they give you is the one you can take to the bank. Answers from local ATF office- eh.... not so much.
So true.

In fact the goblins in milwaukee follow them around cuz the local branch is so inept they often get their full autos and vehicles stolen. Heh.
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Old 03-22-2014, 01:29 AM   #7
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Default Class 01 FFL and AR Assembly

You would be good to go with complete uppers, but you would need a class 7 to sell assembled lowers since that I assembling what is classified as the "actual firearm". That is how it was explained to me.

I applied for a class 7, so I could sell ones I build. Or could sell coated receivers. Apparently coating falls under the modifying category.

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Old 03-22-2014, 09:18 PM   #8
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You would be good to go with complete uppers, but you would need a class 7 to sell assembled lowers since that I assembling what is classified as the "actual firearm". That is how it was explained to me.

I applied for a class 7, so I could sell ones I build. Or could sell coated receivers. Apparently coating falls under the modifying category.

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Did you have to pay ITAR or were you granted an exemption? I want an 07 to make extra money like the OP, but paying ITAR wouldn't make it worth my time.
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Old 03-22-2014, 10:04 PM   #9
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Did you have to pay ITAR or were you granted an exemption? I want an 07 to make extra money like the OP, but paying ITAR wouldn't make it worth my time.

Also getting mine to make extra money primarily coating receivers and parts. Not really to manufacture guns, so no I have not done anything with ITAR.


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Old 03-22-2014, 10:50 PM   #10
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The ITAR regs say all 07s are bound by it, complete BS. Good luck, keep us updated on how things are going. I really want to do the same and I appreciate the information you have to offer.
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