The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) published a Notice of Proposed Rulemaking on May 8, 2026 that would amend its regulations under 27 C.F.R. Part 478 to clarify when firearm frames, receivers, and barrels with both sporting and non-sporting applications may be imported into the United States. Wiley has advised and advocated on behalf of clients regarding this proposed regulatory revision.
ATF is accepting comments on this proposed rule. Submissions are due on August 6, 2026.
The proposed rule would codify ATF Ruling 2025-1 – which addressed dual-use barrels – and extend the same analysis to firearm frames and receivers. Under the proposed rule, federal firearms licensees may import frames, receivers, or barrels that can be used on both sporting and non-sporting firearms if, at the time of importation, there is an identified sporting configuration for the item. Most significantly, and as advocated for by Wiley on behalf of its clients, this would apply regardless of whether the item had previously been configured on a non-sporting firearm, military surplus firearm, or firearm regulated under the National Firearms Act (NFA).
This reflects a significant shift from ATF’s prior approach to dual-use barrels. In a 2005 open letter, ATF took the position that certain barrels capable of use on both sporting and non-sporting firearms were importable only if used to assemble importable firearms. In other words, the importer was restricted in how the barrel, frame, or receiver could be assembled once imported. ATF also considered prior use as part of its analysis and denied permits for barrels previously assembled on non-importable firearms. Under the proposed rule, the relevant inquiry would focus on whether the frame, receiver, or barrel may be assembled in a sporting configuration – not whether the same item also could be used in a non-sporting configuration or had previously been used on a non-importable firearm. The proposed rule also would clarify that once a dual-use frame, receiver, or barrel is lawfully imported based on an identified sporting configuration, it may be used to assemble a sporting firearm, non-sporting firearm, or NFA firearm, provided the assembly complies with other applicable federal firearms laws. In particular, ATF emphasizes that domestic assembly must still comply with 18 U.S.C. § 922(r) and the NFA, as applicable.
ATF explained that its updated approach reflects changes in firearms technology and the increasingly modular nature of firearm parts. ATF acknowledged in the notice that many modern frames, receivers, and barrels can be used in both sporting and non-sporting configurations, making dual-use parts a significantly larger part of the market than when ATF issued its 2005 guidance.
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