A lot of you will be familiar with the TommyBuilt Tactical T36 which is basically a replica conversion H&K G36. The T36 is an expensive but popular choice of firearm for those who want to enjoy some of that sweet German engineering without having to convert an SL8 on their own or go through the trouble of attempting to import a genuine G36. Unfortunately, the ATF recently determined that the methods by which TommyBuilt Tactical machined the T36 receivers were not sufficient enough to prevent easy full-auto conversions and has reclassified the receivers as machine guns. TommyBuilt’s full press-release and explanation of the situation is posted below.

ATF Reclassifies TommyBuilt Tactical T36 Receiver as a Machine Gun

Dear TommyBuilt Tactical T36 Owner:Greetings.  We hope that you are enjoying your TommyBuilt Tactical T36, and want to thank you for your patronage.

With that said, we have received unfortunate news that the receiver of the T36 will now be classified by ATF as a machinegun receiver.  ATF has recently determined that the blocks and restrictions manufactured into our semi-automatic receiver (which are a replica of the SL8 prevention method) are not sufficient and now require an auto sear block on this platform. We disagree with this position but do not make the regulatory decisions.

To this end, we at TommyBuilt Tactical are eager to work with our T36 owners and with the ATF to comply with the newly mandated requirements for this platform. Our counsel and team have met with our regulator to make attempts to resolve this issue.  TommyBuilt Tactical has made and had approved by the ATF an upgraded semi-automatic receiver including more restrictive blocks, the newly required auto sear block and other various upgrades.

So we are clear, there is no current intent by ATF to criminally charge any TommyBuilt Tactical T36 owner for the possession of contraband, or to prosecute TommyBuilt Tactical for any wrongdoing.  To this end, my team and I have been authorized by ATF to replace the existing T36 receivers with an upgraded “TG36” receiver.  There will be a minimal cost to you of $225 to upgrade to the new TG36.  It is critical that you send your receiver to me for an upgrade.  The ATF has made it clear that if your T36 is not returned for upgrade to the TG36, it will be considered contraband and subject to seizure.

Once seized you will lose your entire T36 assembly.  The resolution that we are offering will allow you to keep ALL of your components in an upgraded state at a minimal cost.

We are a small business and already overwhelmed. This unexpected determination is a substantial financial hardship for us all. Please refer to our website (www.tommybuilttactical.com) for more details on this situation and instructions on exactly how to send in your receiver for replacement.

Again, we appreciate your patience and understanding.

While this is par for the course with the ATF, I have to wonder if arbitrary decisions like this will start to become more common as time goes on. Thankfully, it doesn’t seem like current owners will be criminally charged with anything for simple possession of something that was perfectly legal to manufacture and sell just a few days ago, but it is still frustrating to see things like this happen with alarming frequency. My best wishes to the team at TommyBuilt Tactical as they navigate through what has to be a stomach-churning process.