Comment on FR Doc # 2026-09163

I write in support of ATF’s proposed rule, RIN 1140-AA96, “Importing Dual-Use Frames, Receivers, or Barrels.” This NPRM is a positive and overdue step because it recognizes that modern firearms and firearm components are often modular and capable of multiple lawful uses. A frame, receiver, or barrel is not inherently “sporting” or “non-sporting” in isolation. The same component may be used in different lawful configurations depending on how it is assembled. ATF should not deny importation merely because a part was previously used in, or could theoretically be used in, a non-sporting, military-surplus, or NFA-regulated firearm. The proposed standard is a substantial improvement. If, at the time of importation, there is an identified firearm sporting configuration for the frame, receiver, or barrel, then the part should be importable. This is a more practical, consistent, and fair approach. It also properly applies the same logic to frames, receivers, and barrels, which makes sense because the statute refers to those items together. I also support the NPRM’s clarification that once a dual-use frame, receiver, or barrel is lawfully imported, it may be used to assemble a sporting firearm, a non-sporting firearm, or a firearm regulated under the National Firearms Act, so long as the assembly complies with 18 U.S.C. 922(r), the NFA, and other applicable law. Lawful components should not be treated as permanently tainted because of prior configuration or possible future use. If a later assembly violates federal law, that conduct can be addressed under the law governing assembly. But importation of a component with a legitimate sporting configuration should not be prohibited. This rule would also benefit the public and the firearms industry. It would expand lawful sourcing options for importers, manufacturers, gunsmiths, collectors, and consumers. Increased access to lawful imported parts may improve availability, reduce costs, support repair and restoration, and encourage competition. These benefits are especially important for small businesses and individual firearm owners. That said, I also urge ATF and the Department of Justice to recognize the limits of this proposal. The rule still depends on the “sporting purposes” test, which many firearm owners view as outdated, overly narrow, and inconsistent with the full scope of the Second Amendment. The right to keep and bear arms is not limited to hunting, target shooting, or government-approved sporting activity. Firearms and firearm components may be lawfully used for self-defense, training, collecting, competition, historical preservation, and other purposes that are not necessarily captured by a “sporting” standard. For that reason, this NPRM is a positive step, but it does not solve the deeper problem. ATF should apply the sporting-purposes language as narrowly and predictably as possible and avoid using that standard to restrict lawful commerce in common firearm components. The agency should focus on actual unlawful conduct rather than speculative or disfavored uses of parts that are otherwise capable of lawful use. ATF should also provide clear, objective guidance on what qualifies as an “identified firearm sporting configuration.” The final rule should not leave importers and manufacturers guessing about what documentation, examples, or product information will satisfy the standard. If the goal is to reduce burden and increase consistency, the process should be predictable and transparent. Finally, ATF should avoid treating this rule as a narrow discretionary exception that can be easily reversed through future guidance. The firearms industry and the public need stable rules. Importers, manufacturers, retailers, and consumers make long-term decisions based on ATF classifications and import determinations. A clear final rule is preferable to shifting interpretations through open letters or informal guidance. In conclusion, I support the proposed rule because it is a meaningful deregulatory improvement. It recognizes the modular nature of modern firearms, expands lawful importation of dual-use parts, treats frames, receivers, and barrels consistently, and properly separates importability from later assembly requirements. At the same time, ATF should acknowledge that the “sporting purposes” framework remains too narrow and should be applied in the least restrictive, most objective manner possible. For these reasons, I respectfully urge ATF to finalize the NPRM while strengthening the final rule with clear criteria, predictable procedures, and an interpretation that protects lawful firearm ownership and commerce to the fullest extent permitted by law. Respectfully submitted.