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Can I Build an 80 Lower Receiver without an FFL?

Can I Build an 80 Lower Receiver without an FFL - Blog Title Image

If you’re thinking about building an AR-15 at home with an 80 lower receiver (officially called an “80% lower”, like these), you probably have some questions about FFLs and gun laws. Let’s begin!

 

a black, forged 80% lower receiver for an AR-15
A forged 80% lower. This is the most common lower used to build an AR-15 at home without going through an FFL.

 

The Bureau of Alcohol, Tobacco, and Firearms (ATF) says you can build a gun at home without a license:

“No, a license is not required to make a firearm solely for personal use. However, a license is required to manufacture firearms for sale or distribution. The law prohibits a person from assembling a non–sporting semiautomatic rifle or shotgun from 10 or more imported parts, as well as firearms that cannot be detected by metal detectors or x–ray machines. In addition, the making of an NFA firearm requires a tax payment and advance approval by ATF.” – [18 U.S.C. 922(o), (p) and (r); 26 U.S.C. 5822; 27 CFR 478.39, 479.62 and 479.105]

But you might’ve also seen some literature from the ATF (published January 2, 2015) saying this:

Any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver suitable for use as part of a ‘weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,’ i.e., a ‘firearm,’ must be licensed as a manufacturer under the Gun Control Act of 1968 (GCA); identify (mark) any such firearm, and maintain the required manufacturer’s records.” – ATF Ruling 2015-1

What gives?

Why the ATF issued The 2015-1 ruling

Like we said, the ATF has long held that an unlicensed individual can build a gun at home for personal use, no FFL required.

The ATF issued this ruling to address, “whether Federal Firearms Licensees (FFL), or unlicensed machine shops, may engage in the business of completing, or assisting in the completion of, the manufacture of firearm frames or receivers for unlicensed individuals without being licensed as a manufacturer of firearms.”

They’re talking about the 80 lower receiver. More importantly, they’re responding to inquiries from the public asking whether a Federal Firearms Licensee (FFL), or unlicensed machine shop, can assist unlicensed builders (like you) with completing their 80 lower receivers.

Basically the question everyone was asking was:

Can someone else finish my 80 lower receiver?

Unsurprisingly, the answer to that is no. The ATF explains their ruling in so many words:

1. The Gun Control Act of 1968 defines an FFL as “any person engaged in the business of manufacturing firearms or ammunition for purposes of sale or distribution.” As defined by section 921(a)(21)(A) of the Gun Control Act, “engaged in the business” means “a person who devotes time, attention, and labor to manufacturing firearms as a regular course of trade for business with the principle objective of livelihood and profit through the sale of distribution of the firearms manufactured.”

2. When an unlicensed machine shop, gunsmith, or FFL receives an incomplete firearm receiver (an 80 lower, for example), performs manufacturing activity that results in “the making of a different frame or receiver and also a weapon which will or is designed to or may readily be converted to expel a projectile”, and returns it back to the customer or builder (you), he or she has engaged in the “distribution” of a firearm.

3. According to the Gun Control Act, “any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive, i.e., a firearm, must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records.”

Here’s the short-n’-sweet:

  1. The Gun Control Act says an FFL is anyone in the business of building, completing, or distributing firearms.
  2. When someone completes an 80 lower receiver for someone else, he or she is in the business of “building, completing, or distributing firearms”.
  3. Anyone in the business of building, completing, or distributing firearms must be an FFL.

Can I use someone else’s equipment to complete my 80 lower?

Excellent question! Thankfully, the ATF also clarified this in their 2015-1 ruling:

“Held further, a business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on blanks or incomplete firearms (including frames or receivers) using machinery, tools, or equipment under its dominion and control where that business controls access to, and use of, such machinery, tools, or equipment.”

The answer is no.

Why? If you run a machine shop or CNC (even if you’re not a licensed FFL) and you loan out any equipment to anyone trying to complete an 80 lower receiver, you’re now bound by the Gun Control Act’s requirements. That means you need an FFL. If you don’t have one, you’re in trouble.

The easy (and legal) way to complete your 80 lower is with a jig. Officially called an 80 lower jig, these little units cost around $180 to $300. The jig acts like a mini-gunsmithing station in your home, allowing you to complete your lower with your own tools.

You only need a handheld router and hand drill. If you’re ready to build, grab the Porter Cable 6430 Router (it’s the one makers use most to design their jigs). then, grab a jig! the Easy Jig Gen 2 – pictured below – is the most popular jig, but there are more affordable options available here.

The Easy Jig Gen 2 80% lower jig with tooling and router adapter plate
Builders use an 80 lower jig (like this Easy Jig Gen 2) to complete their 80% lowers at home.

Can someone else assemble my 80 lower receiver?

The ATF issued a previous ruling, 2010-10, covering this question as well:

“Section 921(a)(11)(B) defines a ‘dealer’, in relevant part, as any person engaged in the business of repairing firearms or of making or fitting special barrels, stocks, or trigger mechanisms to firearms. A person meeting this definition is commonly referred to as a ‘gunsmith’.”

Besides yourself, only a licensed FFL can assemble or work on your 80 lower.

In order for a licensed gunsmith to work on your 80 lower, it must be adhere to Federal Regulations contained in 27 CFR 478.92(a)(1):

“a licensed manufacturer … must legibly identify each firearm manufactured … [b]y engraving, casting, stamping (impressing), or otherwise conspicuously placing … an individual serial
number” on the frame or receiver, and certain additional information – the model (if designated), caliber/gauge, manufacturer’s name, and place of origin on the frame, receiver, or barrel.
Regulations further require the serial number to be at a minimum depth and print size, and the additional information to be at a minimum depth. Additionally, the serial number must be placed in a manner not susceptible of being readily obliterated, altered, or removed, and not duplicate any serial number placed by that manufacturer on any other firearm.”

Your lower must be serialized, first:

Yes, a licensed gunsmith can work on your 80 lower, but only if it is serialized with the requirements listed above. The ATF clarifies further:

“ATF Ruling 2010-10 assumes that licensed dealer-gunsmiths would perform certain activities on articles already classified as frames or receivers (i.e., no machining or other processes required to allow it to be used to assemble a weapon), such as assembly and applying special coatings and treatments. Implicit is the understanding that the manufacture of the frame or receiver was completed (for example, having an existing fire-control cavity), and it was marked by a licensed manufacturer in accordance with Federal law and regulations.”

Luckily, you can serialize your lower to make it compliant with the serialization requirements of it 27 CFR 478.92(a)(1).

It is 100% legal for you to bring your completed 80 lower to a licensed gunsmith for engraving.

Summary

Too long, didn’t read? Here’s a quick summary of everything:

  • You do not need to be an FFL to complete an 80 lower receiver at home.
  • In 2015, the ATF clarified that no one else can help you build your lower.
  • FFLs, gunsmiths, and machinists can’t loan you tools to build your lower.
  • Anyone who loans you tools or a shop is in violation of the Gun Control Act of 1968.
  • A gunsmith can serialize your 80% lower before or after it’s completed by you.
  • Your lower must be serialized for a gunsmith to do any work (assembly or coating) to it.

 


DISCLAIMER: If you are new to the world of DIY gun building, you likely have a lot of questions and rightfully so. It’s an area that has a lot of questions that, without the correct answers, could have some serious implications. At AR-15LowerReceivers, we are by no means providing this content on our website to serve as legal advice or legal counsel. We encourage each and every builder to perform their own research around their respective State laws as well as educating themselves on the Federal laws. When performing your own research, please be sure that you are getting your information from a reliable source.

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