The letter to FFLs has added significance – as technologies like 3D printing advance from hobbyist levels to professional-grade manufacturing, determining when a firearm is created will be increasingly difficult.
ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames
A complete copy of the ATF open letter can be found at ATF.gov.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is issuing this open letter to assist the firearms industry and the public in understanding whether a “partially complete, disassembled, or nonfunctional” frame of a Polymer80, Lone Wolf, or similar semiautomatic, striker-fired pistol (sometimes generally referred to as “Glock-type” pistols) has reached a stage of manufacture such that it “may readily be completed, assembled, restored, or otherwise converted” to a functional frame, and is therefore classified as a “frame” or “firearm” in accordance with the final rule titled Definition of ‘Frame or Receiver’ and Identification of Firearms (Final Rule 2021R-05F), which became effective August 24, 2022. In particular, the following addresses partially complete, disassembled, or nonfunctional semiautomatic striker- fired pistol frames or parts kits manufactured, sold, or distributed by Polymer80 (known as ‘Poly80’ or ‘P80’ frames or blanks), Lone Wolf (known as ‘Freedom Wolf 80%’ frames), and others, with the characteristics described below.
Summary
Applying the regulatory text of Final Rule 2021-05F, partially complete Polymer80, Lone Wolf, and similar striker-fired semiautomatic pistol frames, including, but not limited to, those sold within parts kits, have reached a stage of manufacture where they “may readily be completed, assembled, restored, or otherwise converted” to a functional frame. This definition of “readily” applies to each and every classification of a partially complete frame or receiver under this Rule, whether sold alone or as part of a kit. Therefore, even without any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, these partially complete pistol frames are “frames” and also “firearms” as defined in the GCA and its implementing regulations, 18 U.S.C. § 921(a)(3)(B) and 27 CFR 478.12(a)(1), (c).
ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames
A complete copy of the ATF open letter can be found at ATF.gov.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is issuing this open letter to assist the firearms industry and the public in understanding whether a “partially complete, disassembled, or nonfunctional” frame of a Polymer80, Lone Wolf, or similar semiautomatic, striker-fired pistol (sometimes generally referred to as “Glock-type” pistols) has reached a stage of manufacture such that it “may readily be completed, assembled, restored, or otherwise converted” to a functional frame, and is therefore classified as a “frame” or “firearm” in accordance with the final rule titled Definition of ‘Frame or Receiver’ and Identification of Firearms (Final Rule 2021R-05F), which became effective August 24, 2022. In particular, the following addresses partially complete, disassembled, or nonfunctional semiautomatic striker- fired pistol frames or parts kits manufactured, sold, or distributed by Polymer80 (known as ‘Poly80’ or ‘P80’ frames or blanks), Lone Wolf (known as ‘Freedom Wolf 80%’ frames), and others, with the characteristics described below.
Summary
Applying the regulatory text of Final Rule 2021-05F, partially complete Polymer80, Lone Wolf, and similar striker-fired semiautomatic pistol frames, including, but not limited to, those sold within parts kits, have reached a stage of manufacture where they “may readily be completed, assembled, restored, or otherwise converted” to a functional frame. This definition of “readily” applies to each and every classification of a partially complete frame or receiver under this Rule, whether sold alone or as part of a kit. Therefore, even without any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, these partially complete pistol frames are “frames” and also “firearms” as defined in the GCA and its implementing regulations, 18 U.S.C. § 921(a)(3)(B) and 27 CFR 478.12(a)(1), (c).