U.S. Department of Justice

Bureau of Alcohol, Tobacco,

Firearms and Explosives

Office of Enforcement Programs and Services

Washington, DC 20226

December 27, 2022

OPEN LETTER TO ALL FEDERAL FIREARMS LICENSEES

disassembled, or nonfunctional” frame of a Polymer80, Lone Wolf, or similar semiautomatic,

striker-fired pistol (sometimes generally referred to as “Glock-type” pistols) has reached a stage

of manufacture such that it “may readily be completed, assembled, restored, or otherwise

converted” to a functional frame, and is therefore classified as a “frame” or “firearm” in

accordance with the final rule titled Definition of ‘Frame or Receiver’ and Identification of

Firearms (Final Rule 2021R-05F), which became effective August 24, 2022. In particular, the

following addresses partially complete, disassembled, or nonfunctional semiautomatic striker-

fired pistol frames or parts kits manufactured, sold, or distributed by Polymer80 (known as

‘Poly80’ or ‘P80’ frames or blanks), Lone Wolf (known as ‘Freedom Wolf 80%’ frames), and

others, with the characteristics described below.

assembled, restored, or otherwise converted” to a functional frame. 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. 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, 18 U.S.C. § 921(a)(3)(B) and 27 CFR 478.12(a)(1), (c).

Background

The Gun Control Act (GCA) defines the term “firearm” as: “…(A) any weapon (including a

the terms “frame” and “receiver” by describing a single housing or structural component for one

specific fire control component of a given weapon—for example, a single housing is specified

for particular weapons such as a “handgun” and a “rifle.” 27 CFR 478.12(a).

The regulation defines the term “frame” in 27 CFR 478.12(a)(1), as “the part of a handgun, or

variants thereof, that provides housing or a structure for the component (i.e., sear or equivalent)

designed to hold back the hammer, striker, bolt, or similar primary energized component prior to

initiation of the firing sequence, even if pins or other attachments are required to connect such

component (i.e., sear or equivalent) to the housing or structure.”

The above list of factors is a non-exhaustive list but represents factors that have been identified

by federal courts as being relevant to a “readily” analysis with respect to firearms. For each and

every assessment of whether any partially complete frame (in the case of a handgun) or receiver

(in the case of a long gun) – whether assessed individually, or in conjunction with other items –

is a “firearm” under the GCA, parties must consider the above definition, including all factors

that are relevant to that assessment. This is true for all frames and receivers.

Analysis

GCA and the Final Rule, the term “readily” does not involve evaluation of a percentage of

completion for an item that, when completed, will function as a frame or receiver. Rather, the

analysis examines how efficiently, quickly, and easily a clearly identifiable component part of a

weapon can be completed, assembled, restored, or otherwise converted to house or provide a

structure for the applicable fire control component. Such analysis may include consideration of

any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing

materials that are, directly or indirectly, sold, distributed, possessed, or marketed with the

component part or kit. As outlined in the above definition, the analysis must consider all factors

that are relevant to the assessment.

install the sear, are therefore crucial steps in producing a functional frame.

In a pistol based on a Glock design, the trigger is housed in the front fire control cavity,

and the sear, which is connected by the trigger bar, is located in the rear cavity.

For reference, in a pistol based on a Glock design, the trigger bar assembly contains the

sear. The trigger bar assembly operates as a single unit.

front slide rail module (known as the “Locking Block Rail System” or “LBRS”), and the rear

cavity provides housing for a rear slide rail module (known as the “Rear Rail Module” or

“RRM”). Under the Final Rule, these slide rail components are “attachments … required to

connect” the sear to the frame. See 27 CFR 478.12(a)(1).

bar assembly is attached to the “Rear Rail Module,” which is attached to the frame.

striker-fired pistols, are also manufactured from a polymer material and incorporate temporary

rails or blocking tabs that are easily removable by a person with novice skill, using common

tools, such as a Dremel-type rotary tool, within minutes—an amount of time and a set of

circumstances that are far less than required to fall within the meaning of the term “readily” in

the Final Rule. Once this material is removed, the partially complete frames are immediately

capable of accepting both the slide rail attachments and fire control components, including the

sear.

set of circumstances that are far less than required to fall within the meaning of the term

“readily” in the Final Rule—with no fitting and no specialized knowledge or expertise. The ease

of obtaining and attaching such items is also pertinent as part of the analysis.

Trigger Mechanism Cavity

Based on the above, partially complete Polymer80, Lone Wolf, and similar pistol frames with

any kind of indexing or material removed from the front or rear fire control cavities for

installation of the trigger mechanism and sear, or slide rail attachments to connect the trigger