An open letter quietly released by federal gun regulators after the government had largely gone home for the rest of the year has big implications for "80 percent" pistol frames.

The 10-page letter to all federal firearms licensees from the Bureau of Alcohol, Tobacco, Firearms and Explosives, dated Dec. 27, is a follow-up to the guidance released earlier this year in the agency's Final Rule 2021-05F, "Definition of 'Frame or Receiver' and Identification of Firearms" rule change. While that controversial rulemaking, which saw almost 300,000 public comments after it was debuted with much fanfare by the Biden administration in May 2021, further muddied the waters on just what was and was not a frame or receiver under the law.

The new guidance, on the other hand, is crystal clear. Importantly issued following the November mid-term election cycle, it classifies most Glock-style "80 percent" complete pistol frames on the market now in the same way as fully completed firearms. 

As detailed by the ATF in a statement, "Partially complete Polymer80, Lone Wolf, and similar striker-fired semiautomatic pistol frames, including, but not limited to, those sold within parts kits, are regulated by the Gun Control Act (GCA) because they have reached a stage of manufacture where they 'may readily be completed, assembled, restored, or otherwise converted' to a functional frame."

GDC Gives Back

The crux of the logic behind ATF's arbitrary change in how the law is interpreted is that some of the 80-percent frames in question use "temporary rails or blocking tabs that are easily removable by a person with novice skill, using common tools, such as a Dremel-type rotary tool, within minutes – an amount of time and a set of circumstances that are far less than required to fall within the meaning of the term 'readily' in the Final Rule."

From the AFT's Dec. 27 10-page letter to FFLs on 80 percent pistol frames.
From the AFT's Dec. 27 10-page letter to FFLs on 80-percent pistol frames.

Meanwhile, a proposed new rule on stabilizing braces of the kind commonly found on AR-style pistols is expected to be released by the ATF before 2022 is over. 

Estimates by the ATF are that a minimum of 1 million Americans would be impacted by the proposed pistol brace rule. Meanwhile, the Congressional Research Service thinks the true numbers could trend as high as 40 million. 

Happy New Year!

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