On December 27, 2022, an ATF open letter to FFLs was published on the ATF website as a guide for the determination of whether pistol frames are completed or can be readily completed into firearms. The determination process is important because it identifies firearms that require record-keeping and background checks or just uncontrolled firearm parts.

More ATF @ TFB:

• ATF Final Rule 2021R-05F (aka 80% Receiver Rule) Explained
• Firearms Transfer Record – Here Is The Newly Revised ATF 4473 – December 2022
• ATF Deems FRTs as “Machine Guns” in Open Letter to FFLs

ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames

The letter to FFLs has added significance – as technologies like 3D printing advance from hobbyist levels to professional-grade manufacturing, determining when a firearm is created will be increasingly difficult. Excerpts of the letter and a link to the complete letter can be found below.

A complete copy of the ATF open letter can be found at ATF.gov.

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is issuing this open letter to assist the firearms industry and the public in understanding whether a “partially complete, disassembled, or nonfunctional” frame of a Polymer80, Lone Wolf, or similar semiautomatic, striker-fired pistol (sometimes generally referred to as “Glock-type” pistols) has reached a stage of manufacture such that it “may readily be completed, assembled, restored, or otherwise converted” to a functional frame, and is therefore classified as a “frame” or “firearm” in accordance with the final rule titled Definition of ‘Frame or Receiver’ and Identification of Firearms (Final Rule 2021R-05F), which became effective August 24, 2022. In particular, the following addresses partially complete, disassembled, or nonfunctional semiautomatic striker- fired pistol frames or parts kits manufactured, sold, or distributed by Polymer80 (known as ‘Poly80’ or ‘P80’ frames or blanks), Lone Wolf (known as ‘Freedom Wolf 80%’ frames), and others, with the characteristics described below.

Summary

Applying the regulatory text of Final Rule 2021-05F, partially complete Polymer80, Lone Wolf, and similar striker-fired semiautomatic pistol frames, including, but not limited to, those sold within parts kits, have reached a stage of manufacture where they “may readily be completed, assembled, restored, or otherwise converted” to a functional frame. This definition of “readily” applies to each and every classification of a partially complete frame or receiver under this Rule, whether sold alone or as part of a kit. Therefore, even without any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, these partially complete pistol frames are “frames” and also “firearms” as defined in the GCA and its implementing regulations, 18 U.S.C. § 921(a)(3)(B) and 27 CFR 478.12(a)(1), (c).

ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames

ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames

Based on the above, partially complete Polymer80, Lone Wolf, and similar pistol frames with any kind of indexing or material removed from the front or rear fire control cavities for installation of the trigger mechanism and sear, or slide rail attachments to connect the trigger mechanism and sear to the frame, have reached a stage of manufacture where they “may readily be completed, assembled, restored, or otherwise converted” to a functional frame. As examined, they are classified as a “frame” and also a “firearm,” as defined in the GCA, 18 U.S.C. § 921(a)(3)(B), and implementing regulations, 27 CFR 478.12(a)(1), (c). They are classified as firearms even if they are not sold, distributed, marketed, or possessed with any associated templates, jigs, molds, equipment, tools, instructions, or guides. While the analysis allows for the consideration of how a partially complete frame is, directly or indirectly, sold, distributed, marketed, or possessed with any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, for these partially complete frames such analysis was not necessary because they are, by themselves, “frames” and “firearms” as defined in the GCA.