Comment on FR Doc # 2026-09163

The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed amendments to the import regulations implementing 18 U.S.C. § 925(d)(3). The proposal advances a more consistent and predictable framework for evaluating the importability of firearm frames, receivers, and barrels while remaining faithful to the statutory language enacted by Congress. Historically, the importation of frames, receivers, and barrels associated with firearms determined to be non-sporting has been subject to significant regulatory restrictions. While those restrictions have reflected ATF's longstanding interpretation of § 925(d)(3), they have also imposed substantial compliance costs and marketplace uncertainty for importers, manufacturers, distributors, and consumers. In many instances, these burdens have not been accompanied by a corresponding public safety benefit, particularly where the imported component has a legitimate and identifiable sporting application. NFATCA believes ATF made a meaningful advancement through ATF Ruling 2025-1 by recognizing that a barrel should not be categorically excluded from importation solely because it is compatible with a non-sporting firearm when there is also an identified sporting firearm configuration for that component. That interpretation more closely aligns the import determination with the statutory sporting purposes analysis and provides greater certainty to the regulated community. The proposed rule appropriately builds upon that interpretation by codifying ATF Ruling 2025-1 and extending the same analytical framework to frames and receivers. Because 18 U.S.C. § 925(d)(3) addresses frames, receivers, and barrels within the same statutory provision, applying a uniform standard to each category promotes consistency in regulatory administration and reflects a straightforward reading of the statute. NFATCA therefore supports the proposed clarification that a frame, receiver, or barrel is importable when, at the time of importation, there is an identified sporting firearm configuration for that component, regardless of whether it may also be compatible with a non-sporting, military surplus, or National Firearms Act (NFA) firearm. NFATCA also supports the proposal to clarify that a lawfully imported frame, receiver, or barrel may subsequently be used in the assembly of a sporting, non-sporting, or NFA firearm, provided that such assembly complies with all applicable provisions of federal law, including 18 U.S.C. § 922(r) and the National Firearms Act. This clarification appropriately distinguishes the statutory criteria governing importation from the separate statutory provisions regulating firearm assembly and possession after importation. Although beyond the scope of this rulemaking, NFATCA believes Congress should also consider whether the restrictions contained in 18 U.S.C. § 922(r) continue to serve their intended purpose. Because § 922(r) is a statutory requirement, its amendment or repeal is appropriately a matter for congressional consideration rather than administrative action by ATF. In NFATCA's view, however, § 922(r) imposes significant compliance burdens and marketplace distortions without providing a commensurate enhancement to public safety. Revisiting that provision could reduce unnecessary regulatory complexity while promoting greater consumer choice and more equitable treatment within the marketplace. Accordingly, NFATCA supports adoption of the proposed rule and commends ATF for providing a clearer and more consistent interpretation of § 925(d)(3). The proposed amendments improve regulatory certainty, reduce unnecessary compliance burdens, and preserve the statutory safeguards established by Congress.