Comment on FR Doc # 2026-09163

To Whom It May Concern: I am writing in support of the proposed rule titled “Importing Dual-Use Frames, Receivers, or Barrels,” Docket No. ATF-2026-0070. This proposed rule is a practical and reasonable clarification of existing law. If a frame, receiver, or barrel can be used in a lawful sporting configuration at the time of importation, it should be importable. Once that part is lawfully in the United States, the location where final assembly occurs should not determine whether the same firearm configuration is treated differently under the law, provided the importer, manufacturer, or licensee complies with all other applicable federal firearms laws, including 18 U.S.C. 922(r), the National Firearms Act where applicable, marking requirements, recordkeeping requirements, and all other ATF regulations. The current uncertainty does not improve public safety. Instead, it encourages more assembly work to be performed overseas before importation, even when the same receiver, frame, or barrel could lawfully be used in a firearm already being imported. In many cases, complete firearms are already entering the United States on the exact same types of receivers or components. Whether final assembly takes place overseas or by a licensed American manufacturer should not create an unnecessary regulatory distinction when the underlying component is the same and the finished firearm is otherwise lawful. Allowing licensed U.S. manufacturers and importers to build on lawfully imported receivers, frames, and barrels would support American jobs. It would move labor, inspection, assembly, finishing, quality control, packaging, compliance work, and related value-added manufacturing activity into the United States instead of forcing more of that work to occur overseas. This benefits American workers, American small businesses, American consumers, and the domestic firearms industry. The proposed rule also recognizes the reality of modern firearms manufacturing. Many firearms platforms are modular, and the same frame, receiver, or barrel may be suitable for more than one lawful configuration. A component should not be treated as non-importable merely because it could also be used in a different configuration, so long as an identified sporting configuration exists at the time of importation and any later assembly complies with federal law. This rule would provide needed clarity to importers, manufacturers, and ATF personnel. Clear rules help the regulated industry comply with the law and reduce inconsistent interpretations. The proposed rule does not remove the licensing, import-permit, marking, recordkeeping, background-check, NFA, or 922(r) obligations that already apply. It simply clarifies that a lawfully imported dual-use frame, receiver, or barrel may be used in lawful domestic assembly. For these reasons, I respectfully support finalizing the proposed rule. It is consistent with the statute, reflects the realities of modern firearms design, reduces unnecessary regulatory burden, supports domestic manufacturing, and will help employ more Americans rather than shifting assembly work overseas.