80% Arms to DOGE: Repeal the Frame‑or‑Receiver Rule Now

Re: Prioritize Repealing the ATF’s Frame or Receiver Rule

DOGE Team,

We appreciate your commitment to reviewing and rolling back harmful ATF regulations. As a company that has manufactured and sold unfinished receiver blanks for law-abiding builders across the country for over a decade, we have seen firsthand how the so-called “frame or receiver” rule devastated both our industry and the rights of millions of Americans.

This rule arbitrarily expanded the definition of “firearm” to include unfinished parts that have never been considered firearms under federal law. It attempted to regulate partially complete, disassembled, or nonfunctional frames and receivers simply because they could be “readily converted,” a term so vague and subjective that it lets the agency decide virtually anything is a gun based on its own opinion.

By doing this, the ATF bypassed Congress completely, creating new categories of regulated items without a single vote from elected lawmakers. Instead of respecting the legislative process, unelected bureaucrats rewrote longstanding definitions, ignoring the constitutional role of Congress. This is regulatory overreach in its purest form and sets a dangerous precedent for future abuses of executive power.

That definition alone gave the ATF unchecked authority to target manufacturers like us and threaten hobbyists with prosecution for exercising a centuries-old American tradition of building personal firearms at home. From blacksmiths and frontiersmen in the 1700s to modern craftsmen working in their garages, Americans have always built and customized their own firearms for personal use. This tradition is woven into the fabric of our founding ideals of self-reliance, liberty, and individual responsibility. The ability of ordinary citizens to arm and equip themselves is exactly what empowered the people to stand up to tyranny during the American Revolution and secure the freedoms we enjoy today. This is more than a hobby or a business; it is a living piece of our national heritage, and no unelected agency should have the power to erase it.

This rule was so deeply flawed that 80% Arms had no choice but to challenge it in federal court as a plaintiff in VanDerStok v. Garland, Civil Action No. 4:22-cv-00691, in the U.S. District Court for the Northern District of Texas, Fort Worth Division. The case is currently under further proceedings on remand following a Supreme Court decision (U.S. Supreme Court Docket No. 23-10718). The confusion the rule created in the marketplace has been staggering. Customers who had legally built personal firearms for years were suddenly terrified of felony charges, and retailers were left guessing which parts would be considered firearms, forcing many to shut down or scale back dramatically. The resulting regulatory chaos made it nearly impossible to conduct business, plan inventory, or confidently serve customers without fear of shifting enforcement.

The rule even tries to classify an unfinished 80% AR-15 lower as a firearm if it is sold with any tools, jigs, or even a simple instruction sheet. The attached graphic shows exactly how the same piece of aluminum becomes a “gun” the moment you include a drill bit or router jig. There is no consistent or objective definition, only the agency’s shifting opinion applied case by case. This echoes the same twisted logic used in the infamous water bottle example, where the ATF claimed a plastic bottle could be considered a silencer because it might be converted. By leaving these determinations up to subjective interpretation, the rule creates a moving target that punishes builders, tools, and knowledge instead of protecting public safety.

This rule destroyed predictability for businesses trying to comply, drove countless small shops out of business, criminalized ordinary hobbyists, and gave the ATF arbitrary power to move the goalposts on what is or is not a firearm. It also forced companies to get approvals and serialize unfinished parts that had never been regulated in decades of prior rulings. And it did all of this with no evidence that it would prevent crime, only to expand the agency’s control.

Repealing the frame or receiver rule should be a top priority. It is the worst example of rulemaking run wild, redefining words to suit an agenda, punishing lawful commerce, and erasing the rights of home builders who have never posed a threat to public safety.

80% Arms fully supports your efforts to fix this. We stand ready to work with you to ensure American businesses and lawful gun owners are not steamrolled again by regulatory overreach.

Thank you for taking this on.

80% Arms