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ATF New Clarification Letter on Unfinished Pistol Frames — Complete Breakdown thumbnail image

ATF New Clarification Letter on Unfinished Pistol Frames — Complete Breakdown

80 Percent Arms   |   Dec 30th 2022

On December 27, 2022, the ATF issued an open letter to all FFL holders to provide “clarification” on how and what the bureau would be considering as a firearm or not.

As we mentioned in our December 30 Newsletter, our legal team has confirmed that due to the protections provided via the injunction granted to us in the VanDerStok v. Garland case, this letter does not apply to 80 Percent Arms’ products.

We’ve got 10 pages in this open letter so let’s dive right into it.


The ‘Summary’ is a brief intro paragraph on page 1 which basically just says that this letter is addressing all “Glock-type” 80 percent pistol frames for which they are now using the term, partially complete. Seems the anti-gunners are always coming up with new buzz words for the mass media to use. You can bet that will start being used in the news soon.

From two key sentences on the first page we can confidently surmise that the ATF is trying to extend their definition of what can be readily completed.

  1. This definition of “readily” applies to each and every classification of a partially complete frame or receiver under this Rule, whether sold alone or as part of a kit.
  2. Therefore, even without any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, these partially complete pistol frames are “frames” and also “firearms” as defined in the GCA and its implementing regulations.

We see you ATF, backpedaling from infringing on the First Amendment huh?


The Background section spends about a page and half from page one to three explaining how the Gun Control Act of 1968 includes “the frame or receiver of any weapon which is designed to or may readily be converted to expel a projectile by the action of an explosive” to be considered as a firearm.

Per the letter, the ATF is making it clear that they intend to treat 80 percent, polymer, striker fired, pistol frames as firearms.


The Analysis portion begins on page three and extends to the end of the letter on page 10. If we really boil down what’s being communicated here, the ATF is fully reversing any (other than for us, 80 Percent Arms) determination letters (though it doesn’t explicitly state that, it is implied) or prior policies they had on allowing the sale of 80% polymer pistol frames.

In fact, they’d have you believe that 80% is just an arbitrary and fake number, made up by marketing departments within the gun industry. Previously, any pistol frame that required plastic tabs to be removed in order to install the front and rear rails; along with critical pin holes to be drilled out by the end user would be considered as an 80% frame.

The ATF is now saying that so long as your frame has a front and or rear rail cavity which is where your front, rear rail or trigger mechanism would sit — that is now considered a 100% frame i.e. a firearm.

Who To Call and Submit Your Questions To

If you have something to say about this letter or need any further information you can contact the following people listed on page 10 of the letter:

Email address —

Phone Number — (304) 616 - 4300

Assistant Director Enforcement Programs and Services — Matthew Varisco

Assistant Director Field Operations — Kristen Detineo