Comment on FR Doc # 2026-09164

Re: Converting Temporary to Permanent Imports for Defense Articles RIN: 1140-AA68 Docket No. ATF-2026-0100 ATF No. 2025R-16P I support ATF’s proposed rule to allow eligible temporary imports of defense articles to be converted to permanent imports without requiring export and reimportation. This is a sensible and overdue procedural reform. If an article is already lawfully present in the United States under a State Department or Commerce Department temporary import authorization, and if that same article is legally eligible for permanent import under existing law, there is no public-safety benefit in forcing the importer to ship it out of the country and then bring it back in. That requirement imposes needless cost, delay, paperwork, and logistical risk while doing nothing to change the legal status or characteristics of the item. The proposed process would reduce waste and may prevent lawful firearms, components, collector items, museum pieces, repair articles, demonstration samples, or other defense articles from being unnecessarily exported or destroyed. That is a positive result for lawful commerce, small businesses, collectors, museums, manufacturers, repair facilities, and ultimately consumers who bear the cost of regulatory friction. Avoiding duplicative export and reimport steps is especially important for small importers and specialty businesses that may not have the resources to absorb unnecessary compliance costs. I also support ATF’s recognition that a conversion process can still preserve regulatory oversight. A Form 6 application allows ATF to review whether the article is eligible for permanent import, whether the importer is properly licensed, and whether the import complies with applicable federal law. In other words, the proposal removes an unnecessary procedural burden without eliminating the substantive review that already applies to permanent imports. However, the proposed rule is too narrow and should not be viewed as a substitute for broader reform of firearm and defense-article import restrictions. The rule does not change the underlying import standards, including restrictions that many lawful gun owners, collectors, and businesses view as vague, outdated, or overly discretionary. In particular, the continued reliance on “sporting purposes” concepts and agency discretion limits the practical benefit of this rule. A firearm or component may be safe, commonly owned, historically significant, useful for lawful purposes, or valuable to collectors and still face import barriers unrelated to misuse or criminal activity. ATF should implement this conversion process in a way that is clear, timely, and predictable. The final rule should require the agency to provide prompt decisions, clear reasons for any denial, and a straightforward appeal or reconsideration process. Importers should not be left with items in limbo while temporary authorizations expire or while storage, insurance, and compliance costs accumulate. The rule should also be administered in a manner that favors preservation and lawful commerce over unnecessary destruction. I urge ATF to adopt the proposed rule because it removes a pointless export/reimport requirement and reduces needless burdens on lawful businesses. At the same time, I urge ATF and the Department of Justice to recognize that this is only a modest procedural improvement. It should be the beginning, not the end, of efforts to make firearm and defense-article import rules more transparent, less wasteful, and more respectful of lawful commerce and the rights of Americans to acquire, possess, collect, repair, and preserve arms.