Comment on FR Doc # 2026-08914

National Firearms Act Trade and Collectors AssociationSupportTrade association
Summary: The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed rule to exempt certain fully assembled training rounds from being classified as "ammunition" for import purposes. They argue that these rounds are designed for specialized training devices rather than conventional firearms and that the exemption reduces unnecessary regulatory burdens while maintaining public safety.
The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed rule clarifying that certain fully assembled training rounds are not "ammunition" for import purposes when they are neither designed for offensive or defensive combat nor designed for use in a device that is a weapon. This interpretation is consistent with the statutory definition of ammunition as material "designed for use in any firearm." As the proposed rule recognizes, these training rounds are specifically engineered for use in specialized training devices rather than conventional firearms and therefore fall outside the scope of the statute. The proposed exemption is both reasonable and consistent with the underlying purposes of the import restrictions. These training rounds serve legitimate and important training functions for law enforcement agencies, military organizations, security professionals, and civilian training programs. Their use enhances the realism and effectiveness of force-on-force training while remaining confined to equipment designed exclusively for training purposes. Maintaining import restrictions on products that do not satisfy the statutory definition of ammunition imposes unnecessary regulatory burdens without advancing any corresponding public safety objective. By clarifying the regulatory treatment of these specialized training rounds, the proposed rule provides greater certainty to importers, manufacturers, distributors, and end users while ensuring that the statutory framework remains appropriately focused on ammunition designed for use in firearms. NFATCA therefore supports adoption of the proposed rule.

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