Comment on FR Doc # 2026-08921

I appreciate ATF's stated intent that this proposed rule is intended only to align ATF's regulations with existing Department of State ITAR definitions and that the rule is not intended to expand the scope of regulated items or impose new obligations on importers. However, I believe the proposed rule would benefit from additional clarifying language expressly stating that the adoption of the definitions of "component," "accessories and attachments," and "part" shall not be interpreted as expanding ATF's regulatory authority or the categories of items regulated under the Arms Export Control Act. ATF states throughout this proposal that the purpose of the rule is administrative consistency and definitional clarity rather than expansion of regulatory authority. If ATF proceeds with this rulemaking, the final rule should expressly state that the adoption of these definitions shall not be interpreted as granting additional regulatory authority or as a basis for expanding regulation to firearms, firearm parts, suppressors, pistol braces, stocks, optics, magazines, accessories, attachments, or any other firearm-related item not already clearly regulated by statute. If the agency's intent is truly limited to consistency with existing Department of State definitions, then the final rule should contain clear limiting language preventing future administrations from relying on these definitions to broaden regulatory control through administrative interpretation alone. Definitions adopted for the purpose of consistency should not later be used to justify additional restrictions, classifications, permitting requirements, enforcement actions, or changes in regulatory treatment that were not expressly authorized by Congress. I also support ATF's proposed clarification that unassembled elements of accessories and attachments should not become regulated merely because they fall within a broad definition of "part." This clarification appears necessary to prevent unintended expansion of regulatory coverage and should remain in the final rule. The inclusion of this clarification demonstrates that definitional changes can create unintended regulatory consequences, which further supports the need for explicit limiting language elsewhere in the rule. Additionally, ATF should consider providing examples or guidance illustrating the distinction between a "component," a "part," and an "accessory or attachment." Doing so would improve public understanding, reduce uncertainty, and further the agency's stated goal of clarity and consistency. Finally, as a citizen and firearm owner, I believe that regulatory definitions should be narrowly construed and should not serve as a mechanism for expanding federal authority beyond that which Congress has clearly authorized. If this rule is intended solely as an administrative harmonization measure, the final rule should clearly and expressly state that it may not be relied upon in the future as a basis for expanding the scope of federal firearms regulation. Thank you for the opportunity to comment.