Comment on FR Doc # 2026-09163

I fully support proposed rule ATF-2026-0070, Importing Dual-Use Frames, Receivers, or Barrels. The proposed rule appropriately recognizes that modern firearms and their components are often modular. A frame, receiver, or barrel may be suitable for use in both sporting and non-sporting configurations. Its importability should therefore depend on whether an identified lawful sporting configuration exists at the time of importation—not on whether the component was previously installed in a non-sporting, military-surplus, or NFA firearm. Extending the dual-use analysis in ATF Ruling 2025-1 beyond barrels to include frames and receivers is logical and consistent. These components are addressed together under 18 U.S.C. 925(d)(3), and applying the same standard to all three categories will provide greater clarity and predictability for importers, other FFLs, manufacturers, collectors, and consumers. As both an FFL and a firearms historian and collector, I believe this rule will produce important practical benefits. Many imported components have legitimate sporting, collecting, restoration, and historical-preservation uses. Permitting the importation of a broader variety of frames, receivers, and barrels will help preserve historically significant firearms and make parts available for the repair or restoration of firearms already lawfully owned in the United States. Destroying or excluding otherwise lawful and useful components solely because of their former configuration serves no meaningful public-safety purpose. The rule should also expand lawful commercial opportunities. Type 08 FFL importers will have access to additional products, while manufacturers, gunsmiths, parts dealers, and ordinary FFLs may benefit from a larger and more competitive supply of components. If I eventually obtain a Type 08 importer license, this rule would increase the range of lawful products and business opportunities available under that license. That is a positive outcome for small businesses as well as consumers. I also support the proposed clarification that, once a dual-use frame, receiver, or barrel has been lawfully imported, it may be used to assemble a sporting, non-sporting, or NFA firearm, provided the resulting assembly complies with 18 U.S.C. 922(r), the National Firearms Act, and all other applicable laws. This properly separates the importability of a component from the legality of its eventual configuration. ATF should adopt the proposed rule. It reflects the realities of modern modular firearm design, provides a consistent interpretation of the statute, expands lawful opportunities for importers and other small businesses, and benefits firearms owners, collectors, historians, restorers, and manufacturers without removing the existing legal restrictions governing firearm assembly.