Manufacturing SBR's


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rpd5127
February 15, 2011, 09:32 AM
Ok, I have got really good over the last few years manufacturing SBR's for myself. So good in fact that I want to start doing it as a business. I have mainly been converting PS-90's , H&K's and AR's into SBR's. I have also done a few Uzi's but mainly want to focus on what I have done the most of.

What kind of BATFE license do I need to manufacture SBR's for my customers if the customer sends me his weapon and I do the work and return it to him as an SBR? I know they have to have a completed Form 1 before any work can be started. I did this with all of mine.

Here is a few pictures of my latest PS-90 conversion ... Which is what I plan on doing the most of.

http://i61.photobucket.com/albums/h47/rpd5127/David/My%20Toy%20Collection/P90/8.jpg

http://i61.photobucket.com/albums/h47/rpd5127/David/My%20Toy%20Collection/P90/3.jpg

http://i61.photobucket.com/albums/h47/rpd5127/David/My%20Toy%20Collection/P90/7.jpg

Thanks,

rpd5127

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Sam1911
February 15, 2011, 10:31 AM
You will need to become a Special Occupational Tax, Class 02 taxpayer as well as having your FFL.

You will actually file a form 5320.2 (notice of firearms manufactured or imported) to let the ATF know what you've made. You will have to transfer it to the owner on a Form 5320.4. The 5320.1 form is only for non-licensed individuals making their own Title II guns.

They will have to send it to you, you "manufacture" the SBR and submit the form 2, and they file their Form 4. You will have to retain possession of the gun until their Form 4 comes back approved.

Birdmang
February 15, 2011, 10:35 AM
Does it just consist of cutting the barrel, threading the barrel and then putting on a new flash hider?

Sam1911
February 15, 2011, 10:43 AM
Does it just consist of cutting the barrel, threading the barrel and then putting on a new flash hider? I see where Birdmang is going with that.

You may be able to simply have barrels sent to you for modification, letting the owner handle all the registration and receiver marking concerns.

Check with the BATFE to find out for sure if they'd let that pass on an 001 FFL (as gunsmithing) or maybe even without.

rpd5127
February 15, 2011, 10:51 AM
It would really depend on the weapon being worked on. For instance, on a PS-90 most end users would not have the tools necessary to remove the barrel from the receiver because the barrel shroud is pinned in place and is a real pain to get off.

I think it would be better to get the FFL/SOT. What does the SOT cost per year?

Sam1911
February 15, 2011, 11:21 AM
I believe the SOT is $500 per year as long as you aren't doing over a certain amount of business.

You will need to hold either a type 07 or type 10 FFL to cover your manufacturing activities. (Not an 001 Dealer/Gunsmith license.)

Check into ITAR as well.

nalioth
February 15, 2011, 12:09 PM
You will actually file a form 5320.2 (notice of firearms manufactured or imported) to let the ATF know what you've made. You will have to transfer it to the owner on a Form 5320.4. The 5320.1 form is only for non-licensed individuals making their own Title II guns.

They will have to send it to you, you "manufacture" the SBR and submit the form 2, and they file their Form 4. You will have to retain possession of the gun until their Form 4 comes back approved.Sam, I believe you're forgetting the other half of the equation.

Individuals with an approved Form 1 can send their parts to any licensed 'smith (including the OP, once he is properly licensed) for assembly/modification/other repair.

Sam1911
February 15, 2011, 12:17 PM
Hmmm... good point. I was getting hung up about the "Manufacturing" angle. If the owner has already filed and received back his Form 1 (and had the engraving done), then I believe he could simply send it with a copy of the Form to a gunsmith for alteration.

Bubbles
February 15, 2011, 01:16 PM
Type 01/C3 if gunsmithing, 07/C2 if manufacturing. SOT is $500 per year, ITAR is $2250 per year for a Type 06, 07, or 10.

ATF draws very distinct lines between gunsmithing and manufacturing, and if you have a Type 01 you do not want to cross them. I'd suggest you read the ATF Gunsmith FAQ (http://www.atf.gov/firearms/faq/gunsmiths.html) and ATF Manufacturer FAQ (http://www.atf.gov/firearms/faq/manufacturers.html) before applying for a license, so you know which type to get.

Sam1911
February 15, 2011, 01:38 PM
ATF draws very distinct lines between gunsmithing and manufacturing, and if you have a Type 01 you do not want to cross them.Thanks Bubbles, that's the very question that has me a bit unsure. I know there are some tasks a few 001s have been doing for some time (assembling AR-15s on stripped lowers, for one) that have gotten them in dutch with ATF who consider that a manufacturing process, not gunsmithing -- even though the 'firearm' is already manufactured, serialized, etc, and they're just adding/altering parts.

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