Comment on FR Doc # 2026-09163

I submit this comment as a Type 07 Federal Firearms Licensee and Special Occupational Taxpayer (a domestic firearms and NFA manufacturer). I support this proposed rule and encourage ATF to finalize it. It is a sound, deregulatory clarification that aligns the regulations with the plain text of the statute and reflects how modern firearm components are actually built and used. I address ATF's specific request for manufacturer input at the end. 1. Codifying ATF Ruling 2025-1 into regulation is the right step. Moving the dual-use barrel determination from a standalone ruling into 27 CFR part 478 gives the regulated community durable, predictable rules with the force and effect of law, rather than guidance that can be revised or rescinded without notice and comment. Regulated businesses make sourcing and capital decisions on multi-year horizons, and codification provides the stability needed to rely on this framework. I support it. 2. Extending the dual-use analysis from barrels to frames and receivers is compelled by the statute. Section 925(d)(3) treats "any frame, receiver, or barrel" together in a single clause. As ATF concludes, the plain language does not support applying one importability standard to barrels and a different standard to frames and receivers. Extending the same analysis to all three is the consistent reading the statute requires, and it eliminates an arbitrary distinction that served no public-safety purpose. I support this extension. 3. The "identified sporting configuration at time of import" standard is the correct test. Replacing the former origin-based approach, which looked backward to the firearm a component was previously configured on, with a test that asks whether the component can be used in an identified sporting configuration at the time of importation is both legally sound and consistent with reality. Modern frames, receivers, and barrels are modular; the same component routinely supports sporting and non-sporting configurations. Tying importability to a component's actual present capability, rather than its history, is the sensible standard, and I support it as proposed. 4. The assembly clarification in new § 478.39(d) provides valuable and appropriate certainty. Confirming that a lawfully imported dual-use frame, receiver, or barrel may be used to assemble a sporting, non-sporting, or NFA firearm, provided the assembly complies with 18 U.S.C. 922(r) and the NFA, resolves real uncertainty for manufacturers. Importantly, this clarification does not weaken any existing safeguard. Section 922(r)'s restrictions on assembling non-importable semiautomatic rifles and shotguns from imported parts remain fully in force, as do all NFA requirements. The rule simply makes clear that lawful importation and lawful downstream assembly are governed by their respective statutes, which is exactly how the GCA is structured. I support this provision. 5. Response to ATF's request for manufacturer comment on economic effects. ATF specifically asked whether domestic manufacturers would benefit from more imported sources of dual-use frames, receivers, or barrels. The answer, from the perspective of a domestic Type 07 SOT manufacturer, is yes. Broadening the pool of lawfully importable dual-use components increases competition and availability among suppliers, which tends to lower input costs and shorten lead times for manufacturers who incorporate a subset of imported components into complete firearms. Greater sourcing flexibility also reduces single-source supply risk. For manufacturers building NFA firearms under an SOT, the clarified ability to use lawfully imported dual-use components in those builds removes a point of legal uncertainty that has previously discouraged otherwise lawful sourcing decisions. These are real, if difficult-to-quantify, benefits, and they support finalizing the rule. Consistent with the rule's severability provision, I encourage ATF to finalize these provisions on their own merits and not to allow disagreement over any single element to delay the rest. Thank you for your consideration.