1.2

License categories

The four kinds of federal firearms licenses and who needs each one

Federal law recognizes four ways a person can be authorized to work with firearms: as a dealer, a manufacturer, an importer, or a collector. Each is defined by what the person actually does. A dealer is anyone engaged in the business of selling firearms at wholesale or retail, anyone engaged in the business of repairing firearms or making or fitting special barrels, stocks, or trigger mechanisms to firearms, or any pawnbroker — and the definition explicitly reaches part-time activity and business conducted anywhere, from a gun show table to an online marketplace. A manufacturer is any person engaged in the business of manufacturing firearms or ammunition, again including part-time operations. An importer is any person engaged in the business of importing or bringing firearms or ammunition into the United States, also covering part-time work. Before commencing any of these businesses, the person must obtain the corresponding license. And except as § 478.50 provides for the locations one license already covers, a license must be obtained for each business and each place at which the applicant is to do business. Which locations a single license already reaches is a question Chapter 2 takes up.

A collector sits apart from the other three. The regulation defines a collector simply as any person who acquires, holds, or disposes of firearms as curios or relics — a term far narrower than either everyday word suggests, reaching only firearms of special interest to collectors for some quality beyond sporting or defensive use, and only within the categories § 478.11 lists. A license as a collector covers only that activity: the interstate transport, shipment, receipt, and acquisition of curios and relics, and disposing of them to other licensees. It does not entitle the holder to engage in a business required to be licensed under the Act. If a collector’s acquisitions and dispositions grow into what the definitions describe as being engaged in the business — selling, manufacturing, or importing — that person must qualify for the license that actually covers the activity, not rely on the collector’s license to cover it.

One efficiency is built into the four-category structure: a licensed importer or licensed manufacturer does not also need a separate dealer’s license to sell, at the same licensed premises, the same type of firearm the license already authorizes them to import or manufacture. The dealer privilege rides along with the importer or manufacturer license for that type of firearm. No such overlap exists for the collector license — it is narrower by design, tied strictly to curios or relics, and a licensed collector is treated the same as a nonlicensee for any firearm that is not a curio or relic, or for any transaction with a nonlicensee involving such a firearm.

Key terms

dealermanufacturerimportercollectorcurios or relicslicensed premisesengaged in the business