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Federal Firearms License | FFL License Application Requirements| FFL Manufacturing License

Applying For The Proper ATF License

In the course of executing the ATF Federal Firearms License Application (ATF Form 7), applicants should define early in the process exactly what type of firearms business they will or may engage in. FFL qualifications and ancillary requirements are slightly different depending on the Type of license required. Applicants should for example, determine if the business activity proposed qualifies as firearms manufacturing. “Building” or “assembling” firearms from component parts has become popular; Federal Firearms License holders who engage in making firearms out of component parts on a regular basis, will likely be considered “manufacturers” by ATF.  Therefore, if you are considering this as part of your retail firearms operations, you should be properly licensed.

firearms manufacturing

Should I apply for a license to manufacture firearms as well as a dealer’s license?

Becoming a FFL dealer may be your only business goal or inclination at this time. However, you might consider the possibility the Type 07 license to manufacture firearms may be required depending on the scope of your business. FFL applicants should determine exactly what type of firearms business they plan to conduct prior to applying. Part of the issue is avoiding the possibility of applying for another license at a later time, when the entire process could be handled immediately.

It’s become popular for people to assemble firearms from component parts for their own use.  However, if a licensed dealer in firearms is assembling firearms from components for their customers as a regular course of business, it is likely that the activity constitutes “manufacturing” by definition, and the dealer should be licensed properly. You should consider this prior to applying, and ensure you apply for and conduct business under the proper FFL license.

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Federal Firearms License

What type of  federal firearms license is right for the type of firearms business I intend to conduct?

There are a number of reasons why it’s important for you as an FFL applicant to determine the exact nature of your business prior to applying for a federal firearms license. The application (ATF F 7) submitted to ATF advises the agency on the proposed firearms business activity. ATF will conduct an investigation based on the information you initially supply and further based on your interview and examination of your business premises. ATF should be aware from the beginning of this process, of the precise nature of your business. Finding out later that a manufacturer’s or other Type license is required will delay the process and may bring the process to an end if not properly addressed.

You want no surprises for the ATF Investigator. Ensure that your application contains the correct information and addresses all possibilities prior to submitting it to ATF. Nothing can be absolutely perfect, but be as thorough and precise as you can be.

Will I be manufacturing firearms?

You may be contemplating a retail firearms business for example, but also intend on conducting activity that requires a manufacturing, or other type license. It’s important that you have a clear understanding of ATF’s definition of manufacturing prior to applying.  For larger firearms businesses especially, this issue requires much thought. Many larger firearms dealers have on-site gunsmiths, perform certain modifications to firearms, or they assemble firearms from components; activities which may put them in manufacturers category. Prior to applying the FFL, you should assess your own business plans and determine weather or not there is a possibility that the activity you will engage in requires a license to manufacture firearms.  Then, as part of the  application process, you can move forward with securing the proper permits and ensuring that your proposed firearms business will not violate state or local law, including zoning ordinances.

These sources will give you some guidance on the issue. There will be more references within each of the documents below as well. 

ATF Ruling 2010-10

ATf Ruling 2009-1

Revenue Ruling 55-342