Comment on FR Doc # 2026-08914
Anonymous AnonymousSupportIndividual
Summary: The commenter supports the proposed rule to clarify that certain fully assembled training rounds are not "ammunition" under the Gun Control Act. They argue that this clarification will reduce administrative burdens, lower costs for youth and safety programs, and promote safer firearms education by increasing access to purpose-built training tools.
I respectfully submit this comment in support of the Bureau of Alcohol, Tobacco, Firearms, and Explosives’ proposed rule, “Importing Training Rounds,” RIN 1140-AA97.
I support ATF’s proposal to clarify that certain fully assembled training rounds are not “ammunition” under the Gun Control Act when they are not designed for offensive or defensive combat and are not designed to be used in a device that is a weapon. This proposed clarification is reasonable, practical, and consistent with the purpose of these products: safe, realistic, controlled training.
Training rounds serve an important educational and public-safety role. They allow instructors, law enforcement agencies, security professionals, youth programs, and responsible firearms educators to teach safe handling, marksmanship fundamentals, judgment, and scenario-based decision-making in a lower-risk environment. When used with proper equipment and supervision, these rounds can help students learn important safety principles before progressing to live-fire training.
I especially encourage ATF to consider the benefits this rule could provide for youth training and educational programs. Many youth shooting-sports, hunter-safety, junior marksmanship, and firearm-safety programs operate on limited budgets. Rising costs, supply constraints, and administrative burdens can make it harder for these programs to obtain suitable training materials. Increasing access to lawful, purpose-built training rounds would help instructors provide safer, more structured, and more affordable education to young people and new shooters.
The proposed rule would also help small businesses, training schools, and instructors by reducing unnecessary paperwork and import restrictions for products that are not designed to function as conventional ammunition. ATF explains that qualifying training rounds are designed for use in specialized training devices or converted training guns, not conventional firearms, and that they are distinct from less-than-lethal ammunition used for riot control or defensive purposes. That distinction is important and should be preserved in the final rule.
In my view, increased access to training rounds would promote responsible education rather than undermine public safety. Better training tools can lead to better-trained users. Making these products more available can help instructors emphasize safe handling, proper storage, muzzle discipline, trigger discipline, and sound decision-making in a controlled environment.
I also support ATF’s decision to codify this interpretation through regulation rather than relying only on informal guidance. A clear rule gives importers, educators, law enforcement agencies, and training organizations more certainty. It also reduces the risk that lawful training activities will be delayed or made more expensive by unclear import requirements.
For these reasons, I respectfully urge ATF to finalize the proposed rule. I also encourage ATF to apply the rule in a way that maximizes lawful access to training rounds for safety instruction, youth education, law-enforcement training, and responsible civilian training, while maintaining the distinction between true training rounds and ammunition designed for combat, defense, or use in conventional firearms.
Thank you for the opportunity to comment.
Respectfully submitted.