https://www.thefirearmblog.com/blog/...rs-as-firearm/
Barreled Actions = Receivers
Then they segue into bolt action rifles. If you think of a traditional bolt action rifle, the serialized portion of the gun is the barreled action. So now the ATF is saying a bolt action upper assembly should be classified as such regardless that it sits on a serialized AR lower.
Non-Standard AR Uppers = Firearms
Near the end of the letter the ATF goes on to say they have previously determined that non-standard AR type upper receivers are considered firearms even when attached to an AR-type receivers. This is a little concerning. I wonder what previous examples are they referring to? The closest example I can think of is the FN SCAR platform. The upper receiver is the serialized portion of the firearm and it attaches to something that resembles an AR-type receiver. However the lower is not a serialized component.
Therein lies the rub. This passage does not mention anything about bolt action receivers. I can see how they could come to the conclusion that bolt action receivers are traditionally considered the firearm and therefore need to be serialized. But now this bleeds over into AR style firearms? The passage above could then be construed that any AR upper can be considered a firearm. This is a slippery slope. If this is the case and all AR receivers are considered firearms then they will need to be transferred via 4473. And of course you can’t just order them online and have them shipped to your house.
Lets hope it does not come to this. But lets take a look at some other issues with this letter. Specifically manually operated AR uppers. Does this mean the upper receiver of guns like the Troy Pump Action Rifle are now themselves firearms? What about a straight pull BCG like the Lantac E-BCG? By installing this have you now “redesigned” the upper receiver and made a firearm? Making your own firearm in of itself is not illegal but doesn’t there need to be a component of manufacturing? Simply assembling components is not manufacturing. Otherwise 80% lowers wouldn’t be a thingMy take: It's a slippery slope, for sure. Even if a bolt action upper counts as a firearm because it's a barreled receiver and that's how bolt actions are classified as firearms, it's not as if the barreled bolt action can be used effectively without the FCG in the lower receiver. You could theoretically disable the gas on a semi-auto upper and operate it manually by finding a way to hit the firing pin. Does that make it a firearm too? I say ATF is over-reaching here.If the ATF presses this new interpretation and enforces it, what happens to all the manually operated AR upper assemblies out in customers hands? Could this issue bleed over to semi auto upper assemblies?
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Originally Posted by titsonritz
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