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Hi folks. I have been assembling AR15 platforms and helping friends build theirs for a while now. I would like to start selling my builds but eventually I would like to buy 80% lowers to mill out, engrave my own logo and serial and assemble to sell. Would that still fall under Type 1 or would it fall under type 7 as a manufacturer? Thanks in advance.
 

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My opinion if using 80% lowers you would need to get a FFL 07 as well as possibly register with the DDTC to comply with ITAR. Since 80% lowers are legally considered just chunks of steel or aluminum not a firearm receiver which you would be manufacturing. On the other hand just assembling a gun from parts should not constitute manufacture. But that is my interpretation based on what I have read, but I am only a FFL 03 and have not done extensive reading concerning manufacturing firearms.
 

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On the other hand just assembling a gun from parts should not constitute manufacture.
Above response is incorrect unless you are assembling for your own use and not for distribution to others.

If FFL holder purchases seperate components (serialed receivers, barrels etc) and assembles parts into a complete weapon for sale (as in this instance an AR) FFL is required to have a manufacturers FFL. if a customer buys the same AR parts independently, (say from Brownells or some other licensed manufacturer), for you to assemble for him you only need a dealer FFL. This is a narrowly defined example specific to the OP AR assembly question posed at start of thread.

I was asked this question recently and called my FFL ATF field agent who confirmed this. When in doubt always confirm with your local FFL ATF field agent contact to clarify.

Specific answer to the OP question posed at the start of this thread is he/she must apply for an FFL manufacturers license. Realize that if you have an FFL dealer license there is no upgrade path to a manufacturers license. The two licenses are independent so if you have a dealer only license, applying for a manufacturers license is a brand new license application that will invalidate the original dealer license once it is issued.

If OP is taking possession of weapon to do work for "friends" without FFL, then OP is not in compliance with federal law.
 

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A 07 FFL is required to assemble AR rifles for sale. If someone buys the parts and brings them to you, a 01 will do, but your customer will probably be paying more. Finishing an 80% requires an 07 for simply completing the receiver. There is a fine line in assembling parts and you only have to get a toe across it to get in serious trouble, call the ATF and discuss it.

Keep in mind, ATF has no definition of 80%, they rule on whether any kit constitutes a valid firearm or not.

Jeff

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