Comment on FR Doc # 2026-08911

Re: Comment in Support of Proposed Rules RIN 1140–AA91 (Update to Proscribed Countries for Import Restrictions) and RIN 1140–AA77 (Adding Component Definitions Under the Arms Export Control Act) Dear Director Cekada and ATF Rulemaking Staff: I write in support of two related proposed rules published by the Bureau of Alcohol, Tobacco, Firearms, and Explosives in the May 6, 2026 Federal Register. Both proposals represent sound, long-overdue regulatory housekeeping that will reduce compliance confusion, align ATF's regulations with current federal policy, and benefit importers and the public alike. I urge ATF to finalize both rules as proposed. I. RIN 1140–AA91: Update to Proscribed Countries for Import Restrictions ATF's proposal to replace the static, outdated list of proscribed countries in 27 CFR 447.52(a) with a dynamic reference to the Department of State's list at 22 CFR 126.1 is the correct regulatory approach. The existing ATF list has not been updated since 2007, creating a growing disconnect between what ATF's regulations say and what current U.S. foreign policy actually requires. That disconnect is not a minor technical inconvenience. It creates genuine compliance uncertainty for importers who must navigate two potentially conflicting lists maintained by different agencies. Because ATF has no independent role in the determination of U.S. foreign policy and is expressly required under Executive Order 13637 to be guided by the views of the Secretary of State on matters affecting world peace and the external security and foreign policy of the United States, there is no principled basis for ATF to maintain a separate country list at all. The proposal to defer directly to 22 CFR 126.1 is not merely administratively convenient; it is the correct structural relationship between the two agencies' authorities. The proposal to remove the former Soviet republics of Georgia, Kazakhstan, Kyrgyzstan, Moldova, Turkmenistan, Ukraine, and Uzbekistan from the blanket import prohibition at 27 CFR 447.52(b) is equally well-grounded. That list was added in 1997 in connection with the U.S.–Russia Voluntary Restraint Agreement, and it reflects the trade and security concerns of a moment that is now three decades in the past. The geopolitical landscape has changed substantially, and a blanket prohibition that treats each of these independent nations as though it remains an extension of Soviet-era Russia is both analytically outdated and operationally unfair to importers who might otherwise seek to source legitimate commercial firearms from those markets. Transitioning to a case-by-case review framework for these countries is a proportionate and modern approach. ATF correctly notes that the Russian Federation import restriction will remain in place pursuant to the continuing terms of the Voluntary Restraint Agreement. That carve-out is appropriate, and the remainder of the proposed revision is well-reasoned and overdue. II. RIN 1140–AA77: Adding Component Definitions Under the Arms Export Control Act The proposal to define the compositional terms "component," "accessories and attachments," and "part" in ATF's regulations implementing the Arms Export Control Act addresses a genuine regulatory gap. The United States Munitions Imports List currently uses these terms throughout its category descriptions without defining them within ATF's own regulatory framework. Importers attempting to determine whether a given item falls within AECA import restrictions must navigate definitional ambiguity that serves no one's interests, least of all those of an importer trying to comply in good faith. Providing clear, codified definitions aligns ATF's permanent import control framework with the definitional structure already present in the Department of State's International Traffic in Arms Regulations. This consistency is important because importers routinely operate across both the export and permanent import control regimes and are best served when the two frameworks use terms in a consistent and predictable manner. Clear definitions reduce compliance costs, lower the risk of inadvertent violations, and make ATF's own enforcement more consistent and defensible. This proposed rule imposes no new burdens on any regulated party. It is a clarifying measure, and its benefits in terms of regulatory certainty substantially outweigh any administrative cost of finalizing it. Both proposed rules reflect responsible regulatory stewardship. They reduce outdated and confusing regulatory provisions, align ATF's framework with current law and policy, and impose no new costs on regulated parties or the public. I strongly support finalization of both rules and encourage ATF to act promptly before the close of the comment period on July 6, 2026. Respectfully submitted,