19 JUL, 2022

Why are there so many firearms manufacturers at the Littleton Mill?

The densest concentration of firearms manufacturers (07 FFLs) in the United States is located in a relatively small mill building in Littleton, MA. This fact is surprising to people that lack a firm grasp of all federal and state firearms laws, but to knowledgeable firearms owners, it makes sense.

I have a friend who is a model train enthusiast. He got into the hobby as a kid when he inherited his grandfather's Lionel trains. Over the (many) years since, he has acquired an impressive collection of trains and accessories, both old and new. Along the way, he learned to repair, modify, and refurbish model trains and was able to fully fund his hobby by buying, refurbishing, and selling trains and related items. He does so well now that it has grown into a profitable side business. This is a hobbyist's dream, right?

What if your hobby is guns?

If you were to substitute "Winchester" for Lionel, and "firearms" for model trains, would my friend have a problem?

The answer is, "Yes" - unless he is properly licensed.

The purchase, sale, repair, manufacture, and modification of firearms is heavily regulated at both the state and federal level. Anyone "engaged in the business" of selling, repairing, modifying, or building firearms must have a Federal Firearms License, also known as an FFL. This publication from the ATF does a pretty good job of explaining when a federal license is required. I say "pretty good" because they use words like "repetitively" and "occasional" without specifying any hard numbers. They recognize this ambiguity with statements like this:

"Federal law does not establish a “bright-line” rule for when a federal firearms license is required. As a result, there is no specific threshold number or frequency of sales, quantity of firearms, or amount of profit or time invested that triggers the licensure requirement."

However, it is quite clear that if you advertise firearms sales or services, perform gunsmithing work for others, or intend to make a profit, you must obtain a federal license.

So why a manufacturer's license?

There are a number of different types of FFLs, but the two that are relevant here are the 01 FFL (dealer/gunsmith) and the 07 FFL (manufacturer). An 01 FFL allows you to sell firearms at a profit and perform simple gunsmithing tasks. An 07 FFL allows you to sell firearms at a profit, perform both simple and complex gunsmithing tasks, and to manufacture firearms for sale. Both licenses cost $50 per year, and have the same application requirements - with one important difference (more on that below).

With that said, the question should be why not get a manufacturer's license? Anything you can do with an 01 FFL can be done with an 07 FFL, and more.

Here's an analogy: Let's say that in the future, there are two types of driver's licenses - one that allows you to drive gas powered vehicles only, and another that allows you to drive both gas and electric vehicles. If both licenses have the same cost and requirements, which one would you get?

A manufacturer's license is required to build guns for sale, or to perform any gunsmithing activity that "improves the accuracy or durability" of a firearm. Since many common gunsmithing tasks fall under this very broad requirement, it is prudent for anyone working on firearms to be covered by a manufacturer's license (07 FFL).

So why the Littleton Mill?

The short answer is zoning and inexpensive rent. Massachusetts law requires anyone engaged in the business of firearms sales or gunsmithing to operate from a location separate from their home. The ATF requires that the FFL's location be properly zoned for the activity. The Littleton Mill is zoned for industrial and retail use, making it possible to get either an 01 (retail zoning) or 07 (industrial zoning) FFL at the location. For reasons explained above, the 07 FFL is preferred.

The Littleton Mill is the safest building in Littleton, and possibly the safest in the United States. Every FFL in the building has been fingerprinted, photographed, background checked to the Nth degree, and interviewed by federal agents. Federal agents from the ATF are there on a frequent basis, and every FFL is inspected annually by the Littleton Police and periodically audited by the ATF.

As for the customers entering the Mill, unlike almost every other state, Massachusetts requires a firearms license (LTC or FID) to possess any firearm, ammunition or ammunition component. As a result, all of the permitted customers coming to the Mill have been fingerprinted and had background checks run on them before they even arrive.

In addition to several retail shops, services at the Mill include training, laser engraving, firearms transfers, grip stippling, firearms refinishing, and gunsmithing. All of these activities require an FFL.

I hope you found this post informative.