Yep, clear as mud. As it has been for quite some time. Different agents and different offices, including the main ATF office give different answers to questions relating to this.
This is the part that likely lead to this new "interpretation"
In addition to limiting the machining work that gunsmiths can engage in, the ruling claims that an FFL not licensed as a manufacturer or an unlicensed machine shop may not allow unlicensed persons to “initiate or manipulate a CNC machine, or to use machinery, tools, or equipment under its dominion or control to perform manufacturing processes on blanks, unfinished frames or receivers, or incomplete weapons.” This portion of the ruling appears to require any business that rents out its machinery or tooling to ensure that the tooling is not used in any part of the manufacturing of a firearm or of a firearm frame or receiver. It’s unclear how BATFE reaches this result without completely rewriting the GCA’s definition of manufacturing, which BATFE does not have the authority to do by formal regulation, much less an informal “ruling.”
This was brought about by the continued making of AR-15 "80% lower recievers" and AK-47's recievers made from generally available flat pieces of steel.
The cat is out of the bag on these and other projects to build receivers by private individuals. Perfectly legal and has been for a long, long time. CNC machines are getting cheap. They are attempting to slow this trend by not allowing the renting of time on such machines.
It is the AR's and AK's popularity that brought this to their attention, but it is quite possible with a CNC to make the receiver for almost ANY firearm. Nor can they go after the programming and instructions for doing this, as that is clearly protected by the 1st Amendment........
