Robinson XCR explains NFA Rules on Pistols

Here is a simple chart that can help explain the nuances of an AR type pistol. The pistol is a 10″ Robinson Armament XCR.

The pictures are relatively self explanatory

Pistol AFG

Pistol bipod

Pistol AOW

Pistol SBR



Those are all the variants that Robinson Armament came up with in this article on EmptorMaven.

I think they left out a variation. Given the recent ruing by the ATF, here is my addition to the list.

Pistol Sig

Nicholas C

Co-Founder of KRISSTALK forums, an owner’s support group and all things KRISS Vector related. Nick found his passion through competitive shooting while living in NY. He participates in USPSA and 3Gun. He loves all things that shoots and flashlights. Really really bright flashlights.

Any questions please email him at


  • Ken

    I wonder if it’s legal to put a rifle length buffer tube on an AR pistol.

    • Cymond

      Yes, dig around in the ‘pistols’ section of Arfcom, there’s a letter stating that an A1/A2 buffer tube is legal on a pistol, as long as you don’t attach a stock.

      • HSR47

        It looks like BATFE has rearranged their site; If you google the actual file name, the letter should come up…

    • echelon

      It is *legal* but if you are found to also be in possession of a stock that will fit that buffer tube then you’re up the S creek.

      Just get a KAK Industries tube and the brace and you’re ready to go!

  • 360_AD

    As usual, RA is a little behind the ball. Since they came out with their own proprietary stock design, they’ve stopped producing the M4 buffer tube stock adapter; both fixed and folding versions. In doing so, they’ve probably missed a lot of sales potential. Then again, they have trouble keeping up with existing orders already. More sales probably do them more harm than good.

  • Blake

    Good article; this clarifies things effectively.


  • me ohmy

    still made by a company that sucks,
    still has terrible after sales service,
    still has an a**hole method of thanking their customers for buying their still crappy products.

    • JumpIf NotZero

      I don’t own one. But the last carbine class I went to, a guy ran an XCR hard on the range. No lube. Fair ammo. Acog. Not only did he have zero issues with jamming up or not feeding, but during the precision shots he was getting out to 700y and 800y. Completely factory gun, I was pretty impressed.

      You can simply not own one if you don’t like them, but I’m. It sure it furthers you to just blindly slam them as “crappy”.

      • me ohmy

        try to find parts…for that XCR. seen and found to be unobtainium, also they tell you point blank “don’t f**k with us, or bitch about waiting times, or we’ll make you wait longer…” that *IS* a verifiable fact
        AR-15 and TAVOR arent hard to find parts for, IMI is very very customer conscious and at least a bazillion places for AR parts..
        also four available after market trigger groups including geissele make the TAVOR better then an AUG wishes it ever was for trigger pull.
        and you need to read more, seen plenty of OTHER articles here where owners of their ROBINSONS said plainly… they sucked, Their service sucked, and the owner is an classless ball busting a**hole, who tells his employees ” release your inner dickhead and f**k with the people who bought our crap and need to have it fixed, and are pissy because my over expensive crap failed on them” .
        frankly, I’m glad that ACR works well.. but even a stopped clock is right twice a day.. and I don’t buy into fan boys sucking the hind end of Bill Ruger wannabe control freak a**holes.

        • JumpIf NotZero

          Well, good thing you have it all figured out!

          • me ohmy

            yep… it’s good to be the king..

        • Jack

          Love my XCRs. Tolerate the company. I’m an FFL and have been selling spare parts when I can get them. Wait times have been between 5 weeks and 18 months. Not joking.

          It’s a robust platform that’s easy to work on. It has a lot going for it. It’s just a shame Alex doesn’t sell the design to someone that can get it to the masses.

        • iksnilol

          AUGs can use AR triggers, Rat Worx makes a conversion.

          • me ohmy

            Dude.. RAT WORX HTM might be vapor ware.. seen hits and hints.. but no real good intell and the website has no love for the hybrid trigger set up..
            I need me a TAVOR!!!!!!!!!

      • That’s why I have a Timney trigger on my Tavor

        • kingghidorah

          That is a shame after laying out a nearly 2k on a rifle, the stock trigger is a pos. Still cool, ergo and reliable, but I’ll wait until they drop into the sub 1k range- if that ever happens.

      • Airman596

        It’s surprising Robinson Armament is still in business. I don’t have anything against the company and I wish they would improve their customer service and quality control because I think the XCR is an interesting design and I would like to own one. However, I’m going to avoid the XCR. Robinson Armament has a poor reputation on gun forums and blogs and they don’t appear to care. I hope that changes in the future as I still hold out hope that I might buy an XCR one day. It’s a shame when a good design is held back by its designer’s ego.

  • Cymond

    Also, they seem to have missed the part where a “pistol” that is over 26 inches can have a vertical foregrip. If you have a SB-15 on your pistol, there’s a decent chance you’re over 26″.

    • JumpIf NotZero

      I’m not sure I’ve seen that time you are talking about. The only determination on 26″ I’ve ever seen is that even with a 16″ barrel the rifle still must be over 26″.

      An issue of being too short with the Tavor for example.

      • Risky

        If it is over 26 inches in length, then it isn’t considered an AOW regardless of whether or not it has a forward grip. It’s how the pistol grip only shotguns work without being considered AOWs, they’re just long enough.

        • gunslinger

          i think it is considered “a firearm” it’s not a pistol because it’s over 26″. It’s not a shotgun because it’s not a shotgun. it’s not a rifle because it doesn’t have a stock. it’s not an SBR because it’s not a rifle first. not a short barrel shotgun because not a shotgun. it’s not an AOW because it doens’t meet those criteria.

      • Cymond
    • Gabe

      Some state also dictate what a pistol is by barrel length. For example, in Georgia a pistol is defined as having a barrel that does not exceed 12 inches.

      • Cymond

        You’re right, but this is discussing federal law. I think Michigan requires special paperwork on any rifle under 30″. Also, Pennsylvania defines ‘handgun’ as anything with a barrel less than 16″. That means someone with a CCW can carry a SBR in PA.

        • floppyscience

          Michigan got rid of that rule a couple years ago. Now they just follow federal law and consider 26″ the minimum for rifles.

  • Vitor

    Wow, the AOW thing is ridiculous, a 5 bucks fee, it takes 10 months to the bureaucrats resolve it and if you dont wait…10 years in prison. Because those super lethal vertical fore grips.

    • H92

      solution: monopod

      • Maximilian Johannes Benning

        Is that a legitimate way to get around it or would the monopod still be considered a VFG? also, what about a foregrip-bipod?

        • gunslinger

          i would venture a guess that a monopod would be considered a VFG. sure you could test it, get arrested, go to trial and open up a new can of worms…

          but what about the bipods that collapse to a VFG? much like the arm brace, the intended use is a bipod.

          • Cymond

            I believe I saw an ATF determination letter that stated that ‘GripPods’ and similar are still considered vertical foregrips.

          • Jim88

            Citation would be nice…

      • Federalist

        Unfortunately no: ATF says a VFG that happens to have/deploy a pod is still a VFG.

        • H92

          what if it’s fixed?

          • Evan

            I believe they still consider it a VFG.

    • CaptainSlaughterboard

      And even bureau people don’t think AFG is enough lethal heheh

    • John Daniels

      It’s only $5 if you’re transferring an existing registered AOW from a dealer on a form 4. If you’re “making” a new AOW, that’s a form 1 and a $200 tax stamp.

    • Kivaari

      A problem for the owner is the gun has to be created by using an ATF Form 1 and it costs $200 to “Make and register” the new AOW. It pays to buy it from a manufacturer already configured as an AOW. If you do it after you buy the gun as a pistol, it big bucks. After it is made it only costs $5 to transfer it to another. The waiting period is crazy. I did 7 SBRs it took between 45 days and 9 months nearly 30 years ago. The slowest to get approved was a TC Contender in .45 Colt/.410. That confused the examiner as it was thought to be both a rifle and shotgun. After 9 months, I called the NFA branch and spoke to a supervisor. She said, “Is that all that is?”, I replied “Yes”, and she approved it.

  • numbnuts

    yep , makes perfect sense .. NOT

  • John Bear Ross

    Pretty crappy, no, how the length of a piece of metal pipe can be the determining factor in a felony conviction? The NFA is a crock.

    • Kevin R. Cross

      It’s why I don’t feel as annoyed by the ATF as I once did. These poor guys have to work with wonky, unworkable laws, try and make the whole thing function, and enforce the law on what is (for a fedral agency) a shoestring budget. I still don’t like the bureau, but I have a lot more sympathy for the agents.

      • Bronson

        But they choose to work that job. No one is forcing them to aid in unconstitutional activities, in fact they’re getting paid for it.

        • Kevin R. Cross

          Except that 90% of what ATF agents do is not unconstitutional. Blaming an entire agency for the actions of a small number is unreasonable.
          Blaming the HEADS of that agency for allowing such, however, is quite fair and just.

  • Airman596

    The NFA makes my brain hurt. You can serve more time in prison for violating the NFA than some rapists and child molesters. We live in interesting times.

    • Michel_T

      Makes you wonder… doesn’t it.

  • Blake

    Mkay, so imagine just theoretically, you’ve built up a short-bbl AR15 “pistol” with:

    • angled foregrip or monopod
    • rifle-length buffer tube
    • SIG arm brace

    You’re at your local range shooting it from the shoulder and a LEO is there & asks you if you’ve registered your SBR. Your AR frankenpistol looks a heck of a lot like an SBR, so (s)he is fully justified in asking you about it.

    Even if you know that you are within the law & carry around a printout of the ATF letter explaining that the SIG arm brace is “not a stock”, this hypothetical situation could get you in a lot of trouble, possibly requiring legal assistance…

    I see a few potential outcomes:

    • somebody high-profile or well-financed enough gets into this situation & wins the court case: yay, frankenpistols for everyone
    • somebody high-profile or well-financed enough gets into this situation & loses the court case: no more frankenpistols for us & SIG stops selling arm braces
    • less well-heeled people get caught up in this & go to jail

    This guide is a good start, but if manufacturers and enthusiasts are going to be encouraging this sort of build then said manufacturers need to pay a lawyer to draft an illustrated PDF that can be easily printed up. It would look a lot like this article but also include references the relevant court decisions, laws, ATF opinions, etc.

    Put simply: Manufacturers: it is in your interest to keep your customers out of jail due to law-enforcement confusion over poorly-written firearms laws.

    • echelon

      Just print the ATF letter that states that firing from the shoulder is OK. The inquiry was sent to the Firearms Technology Branch by a Sheriff in Colorado who was in the exact situation you postulate. He saw someone at a local range shooting the brace from a shoulder. Rather than go off half-cocked he decided he’d write the ATF to get the official word.

      If you were to be falsely arrested and you showed both of the ATF FTB letters to the judge I don’t see how they could proceed with any charges.

      • gunslinger

        citizen… pick up that can. that’s how.

        • echelon

          You lost me…

          • gunslinger

            From the video game half life 2, when you start the game it teaches you the controls and such. One encounter has a cop knocknig over some garbage, then telling you to pick it up and trhow it way. if you don’t you can’t pass. if you throw it at the cop, you get beat.

            it’s sort of become a thing meaning the police/government thinking they are better than you and forcing you to do silly things.


          • echelon

            Gotcha. I’d missed that one. Played the game but didn’t realize it became a meme.

            And sure they could pull that and it’s be a waste of time and money but I still think the case would get thrown out…but yeah they could be dickish about it if they want to. It’s not like we have the rule of law in this country anymore anyway…that’s demonstrated every day!

      • Michel_T

        That’s nice of the sheriff to not go crazy… but seriously, don’t they have better things to do than worry about the legality of how a guy is shooting his pistol at a shooting range?!?!

        I am sure there are plenty of rapists, molesters, thieves and crooked politicians to catch in Colorado…

        • echelon

          For sure.

          Well…they can’t enforce the pot laws anymore so most of them probably have plenty of time on their hands now…

          Plus NFA laws are harsh…10 year prison sentence and 250k fine…maybe that’s a good bust for the cop to have on his resume, I dunno…

    • Cymond

      If the LEO ignores a letter from the ATF stating that it’s legal, what makes you think any other documentation is going to matter? Wrongful arrest is always a possible problem for anyone doing anything. All we can do is to stay legal and keep documents proving that our guns are legal.

      I once read a blog post from a man who (in his youth) was arrested, convicted, and sentenced for doing something that was not illegal. What he had done seemed like it would be illegal, yet there was no law against it in his jurisdiction. He was convicted of a felony for something that was NOT illegal. Neither the arresting officer nor the judge realized there was no law against his actions. Worse, his is now a ‘prohibited person’ in the eyes of the ATF. He has since hired a lawyer to have his conviction “erased” and it was. However, ATF only keeps incoming legal documents for a limited time, so they keep ‘forgetting’ that he is not a prohibited person.

      Unfortunately, I can’t remember enough of the details (name? article title? blog?) to re-find the post.

    • Blake

      all good points.

      But my point is that like any other product around which there is legal confusion (e.g. radar detectors, etc etc), the *manufacturers* need to step up to the plate and inform their customers that their product could get them in deep doo-doo if they don’t know the letter of the law & carry a printout or leaflet or something (preferably one that came with the product) explaining why their frankenpistol isn’t an NFA item (& I’m not just talking about SBR, AOW qualifies too).

  • McThag

    $5 to TRANSFER an AOW, $200 to MAKE one.

  • Risky

    Actually the part about the AOW is somewhat incorrect. The $5 tax for AOW’s is for the transfer of one already made. If you ‘manufacture’ an AOW yourself by adding a vertical grip to a pistol, the tax stamp is still $200.

    • Yellow Devil

      Nice to know I “manufacture” my AR every time I take off or put on my vertical grip.

  • Paul White

    further evidence of just how fubard’d the NFA is.

  • avconsumer2

    It’s like those multitude of stupid, outdated laws still on the books that aren’t enforced like “It’s illegal to dance in Des Moines between the hours of 2 a.m. and 6 a.m.” or “women can’t wear patent leather shoes in Cleveland”… just soooo idiotic.

    But seriously… say one day you decide to go all Jesse James / public enemy #1 down at the range, and (omg… I shudder even thinking it…) actually slip a vertical fore-grip onto your “pistol”… how many LEO’s (federal or otherwise) are there that would realistically drop what they’re doing (& or train their weapon on you,) and demand that you disarm, cuff you, & drop some Miranda on your ass…. cause you have a friggin fore grip on your damn “pistol”.

  • Jim Jones

    Sheer stupidity, illustrated for all to see.

  • jamezb

    The NFA is up on the crack.

    Be very glad they don’t regulate the “Thing that goes up”

  • jamezb

    Why is a front strap (ala Mac-10) cool but not a K-grip?

  • opie

    Theres more to it than this article points out if the pistols overall length is 26 inches its just a “firearm” not a pistol or rifle so therefore you can legally add a foregrip.

  • thinglet

    The NFA needs to go away yesterday.

    • Barry Hirsh

      RATHRIN!!! (Character “Gabby Johnson”, Blazing Saddles)

  • Barry Hirsh

    As indicated below by “thinglet”, the NFA is STÍNQUE!

  • aorobert

    How about a horizontal grip?

  • BuzzKillington

    Question: Where does a stubby VFG fall into this? It’s not exactly a vertical grip as much as it is a handstop like the Magpul AFG. Does it still constitute an AOW or does are they good to go on pistols?

    • Federalist

      There’s no basis in law for regulating pistols with extra grips in this fashion. So the ATF is making it up as they go along, and AFAIK they haven’t gotten to the question of VFGs that are too short to afford a vertical grip.

      • BuzzKillington

        I appreciate it. Unfortunately with them, it’s always best to err on the side of caution. But even despite ATF’s lack of specifics and even their already established laws, local law enforcement is ignorant to it all. I’ve read more stories than I can count of local LEO’s not knowing a thing about Title II weapons. I’ve heard of guys who even after showing proof of NFA stamps, were detained for hours and had their firearms confiscated because the idiots were clueless. I’ve also read where paperwork was shown for things that the cops didn’t even know paperwork was required. So you just never know what kind of cop you’re going to get and what kind of issue you might run into.

  • joew

    You also missed that as long as the firearm is over 26in it is not a pistol or rifle but just a firearm. When a firearm is over 26in and does not have a stock that makes it designed to be fired from the shoulder, any length of barrel is good to go as well as a vertical foregrip.

  • eagle37091

    If the pistol is over 26 inches OAL you can run a VFG, in the BATF’s opinion but they also have said it does not fit the classification of a AOW (must be 26 inches or under).