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Manufacturing – Manufacturing v. Gunsmithing When Modifying for State Compliance

posted on January 18, 2019

Q: I would like clarification on the standpoint of manufacturing vs gunsmithing. During an ATF seminar last week, the Phoenix DIO stated specifically that modifying a firearm for the purpose of resale for profit was manufacturing and modifying one already owned by the customer was gunsmithing. This included something as simple as changing sights. She went on to state that the difference was directly related to the ownership of the firearm. I take this to mean that installing a Bullet Button on an AR type gun going to CA would be considered manufacturing unless already owned by the customer. If the customer has paid in full for everything, but the gun has not been shipped or had a 4473/NICS check completed, is the mod considered gunsmithing? How does this translate into other state ban mods?

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