When does a manufacturer become a firearms manufacturer?

[Simonpie]

So I cruised around the ATF web site and couldn’t find an answer. I hope there are some people here who might point me in the right direction. At what point does a manufacturer of gun accessories need a federal manufacturer or gunsmith license? For instance, it seems a leatherworker who makes rifle slings doesn’t, but I know that someone who takes guns to do engraving and refinishing does. Where’s the dividing line? Specifically, what about making sighting knick-knacks like scope rings?
Links to law are more appreciated than opinion.
Thanks.

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[mcathcart]

Googlefoo son.

Firearms - How To - Become An FFL | ATF

<broken link removed>

 

[Simonpie]

I figured you guys would have the answers. It looks like you don't need squat unless you involve a receiver in some way. Sweet.

 

[Mark W.]

#2.
You can even be a Gunsmith and not need a FFL if you do the work while your customer waits for the work to be done.
If your customer has to "leave" the gun with you, then you need an FFL.

Classic example of government foolishness.

Well yes and no. At our Clubs annual sight in service where we open the range up to the public and assist them in sighting in their hunting rifles. We have a couple of very knowledgable guys that operate a workbench. They make sure rings are tight and alinged they bore sight the rifles if need be they perform some very basic adjustments.

By doing this work while the owner is standing there waiting these guys do not have to have a FFL. So there is an advantage to the silly rule.

 

[MountainBear]

The problem with this type of rules are that they are arbitrary. Ask ten different ATF agents and get ten different answers. Some say if you are providing the receiver for a clients project. Others say if you are changing calibers. Other definitions I have heard are even looser. Bottom line is that most the gunsmiths I know just get a manufacturers license when they get their FFL. Last guy I talked to said it actually cost like $25 less to get his type 7 FFL (manufacturer) rather than a standard dealer FFL. Interesting. I'll find out in about seven months when I start my application process...

 

[Simonpie]

Just one example.



Simple refinishing is not being a manufacturer.

Q: Is a license needed to engage in the business of engraving, customizing, refinishing or repairing firearms?Yes. A person conducting such activities as a business is considered to be a gunsmith within the definition of a dealer.
[27 CFR 478.11]

Just reread this. I guess my concern was not between gunsmith vs. gun manufacturer, but rather between general manufacturer vs. gun manufacturer. Either type of ATF paperwork would be more hassle than I'm interested in.