Q: In CA there is a “not unsafe gun” roster that all firearm to be sold to regular individuals are required to be on. These must be drop tested etc and the manufacturer must pay the fees to keep them on the roster. There is an exemption to this roster for single shot pistols of a certain barrel length, such as a Thompson Contender type of pistol. There are a number of dealers doing “single shot conversions” on non-rostered pistols to bypass the rostering requirement. This consists of installing a longer barrel usually and a “0 shot” magazine block. ATF has told us that this requires a manufacturing license, but there are many dealers who do not have them who are doing this. I am under the impression that in previous rulings and advisories, the ATF has taken the position if installing modifications with parts that are “drop-in” (with no gunsmith fitting required), that it does not constitute manufacturing. As I understand it, ATF is taking the position that installing these parts make it more marketable and must be done to be sold, therefore it is considered manufacturing. I have a manufacturing license in another state that I could use for this, if necessary, but it is more costly to ship them away to install non-gunsmithing parts.
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