Make your Voice Heard!

News from Reeves & Dola, LLP

(ATF) published this summer as part of its efforts to modernize the regulations governing firearms and ammunition. What you may not realize is that ATF needs and is strongly encouraging industry to comment on these proposed regulatory revisions. There are several proposed rulemakings for which the comment period is due to close in the next few days. Participate! Do not take the rulemaking process for granted. The notice and comment period is a unique and valuable opportunity in the United States for members of industry and the public to educate and inform the governing agency about the impact regulatory change will have on lawful business operations.

Below is a list showing some of the proposed rulemakings that are closing soon for comment. The list includes direct links to the respective pages on regulations.gov, the official U.S. government website through which you can view the proposed rulemaking document and provide comments. In the interest of time and space, not every proposed rulemaking is listed below. You can view all the ATF rulemaking publications on regulations.gov.

Comment Period Closing Aug.4, 2026, 11:59 PM EDT

• RIN 1140-AA97 Importing Training Rounds – Amend regulations to clarify that certain training rounds are not controlled for permanent import as “ammunition.”
• RIN 1140-AB01 Regulations Defining Engaged in the Business as a Dealer in Firearms – Amend regulations to remove Justice Department additions to statutory definition that created rebuttable presumptions of being engaged in the business of dealing in firearms.
• RIN 1140-AA73 Clarifying Interstate Transportation of Firearms under the Gun Control Act – Amend regulations to clarify that activities reasonably necessary to transportation are protected under the GCA provisions allowing interstate transport of firearms. Examples of such activities include staying overnight in temporary lodging, stopping for food, fuel, vehicle maintenance, an emergency, or medical treatment, or transiting between modes of transportation.
• RIN 1140-AA69 Definition of Engaged in the Business – Amend regulations to clarify that the term “business premises” includes properties that adjoin each other; or that are adjacent to each other and adjoin the same parking lot, sidewalk, or road.
• RIN 1140-AA95 Firearm Records Retention Periods – Proposal to require federal firearms licensee acquisition and disposition records be retained for 20 or 30 years rather than for an indefinite period.
• RIN 1140-AA98 Removing Factoring Criteria for Firearms with Stabilizing Braces – Pursuant to court decisions enjoining, staying, or vacating a 2023 final rule making firearms with certain stabilizing braces subject to National Firearms Act Controls, ATF is now proposing to remove the language added under the 2023 rule.
• RIN 1140-AA78 Firearms Transactions and Straw Purchases – Amend regulations to provide clarity for conduct prohibited by federal law commonly referred to as a straw purchase.
• RIN 1140-AA85 Clarifying Exceptions to the Brady Act Background Check Requirement – Amend regulations to clarify when a state’s firearms-related permit meets the requirements under the Gun Control Act as an alternative to the National Instant Criminal Background Check System check.

Comment Period Closing Aug. 6, 2026, 11:59 PM EDT

• RIN 1140-AA68 Converting Temporary to Permanent Imports for Defense Articles – Amend regulations to allow importers to apply for ATF authorization to convert items lawfully imported temporarily—under a Department of State authorization or under the entry clearance requirements for temporary imports in the Export Administration Regulations maintained by the Department of Commerce—to permanent imports in compliance with other applicable federal firearms laws, without having to export and then reimport the items.
• RIN 1140-AA93 Firearm Activities in FTZs, CBWs – Amend definition of “importation” to exclude import requirements for items brought into a customs-bonded warehouse (CBW) in addition to the existing exclusion for a foreign-trade zone (FTZ).
• RIN 1140-AA94 Firearms Electronic Recordkeeping – Amend regulations to authorize federal firearms licensees (“FFLs” or “licensees”) to generate, maintain, and store records in an electronic record-keeping system.
• RIN 1140-AA96 Importing Dual-Use Frames, Receivers, or Barrels – Amend regulations to clarify that federal firearms licensees may lawfully import “dual use” frames, receivers, or barrels (may be used on both sporting and non-sporting firearms) if, at the time imported, there is an identified firearm sporting configuration for the frame, receiver, or barrel.
• RIN 1140-AA88 Defining “Willfully” for Firearms Violations – Amend regulatory definition of “willfully.”

Participate in this important process. ATF will review all comments and take each into consideration when finalizing the proposed changes. If you will be impacted, now is your chance to comment on clarity, the costs and benefits of the proposed rule, especially reduced burdens, where applicable. If you are in favor of a proposed rulemaking, MAKE THE COMMENT. Positive comments will help the agency build an administrative record to protect against legal challenges. Time is running out so act now.

About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs. Learn more at https://reevesdola.com/. Join their mailing list and stay informed of industry news.