ATF publishes regulatory actions to modernize and streamline firearms, ammunition, and defense trade

In May 2026, the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) published 34 regulatory actions in the Federal Register. Eight of these actions address the permanent import of firearms, ammunition, and defense articles. The actions include six proposed rules, one direct final rule, and one final rule.

Collectively, these actions represent a focused effort by ATF to reduce regulatory burdens on importers of firearms, ammunition, and defense articles; align its regulations with the Department of State’s International Traffic in Arms Regulations (ITAR) and the Department of Commerce’s Export Administration Regulations (EAR); and modernize outdated provisions.

The regulatory actions align with the Trump Administration’s deregulatory agenda under Executive Order (EO) 14192, “Unleashing Prosperity Through Deregulation,” and EO 14294, “Fighting Overcriminalization in Federal Regulations.” ATF has characterized most of these actions as deregulatory in nature, imposing no new costs on industry while providing increased flexibility and reduced administrative burdens for importers of firearms, ammunition, and defense articles.

In this alert, we provide a brief overview of the proposed rules, direct final rule, and final rule; discuss the key changes; and identify practical implications for businesses involved in importing firearms, ammunition, and defense articles.

Overview and practical impacts of the regulatory actions

The eight actions address different aspects of ATF’s import regulations under the Arms Export Control Act (AECA), Gun Control Act (GCA), and National Firearms Act (NFA). Two of the actions are final rules that take effect shortly after publication, while the remaining six are proposed rules that are open for public comment.

1. Update to proscribed countries for import restrictions

ATF proposes to remove the outdated list of proscribed countries at 27 CFR 447.52(a), which has not been updated since 2007, and replace it with a general reference to the Department of State’s list at 22 CFR 126.1. This proposed amendment would result in a policy of denial for imports of defense articles and defense services originating from countries that are 1) identified in 22 CFR 126.1(d)(1) and 2) subject to a policy of denying imports of defense articles as specified in 22 CFR 126.1(d)(2). The proposed amendment would retain the catch-all language that enables ATF to apply a policy of denial for imports of defense articles and defense services in any case in which an import would not be in furtherance of world peace and the security and foreign policy of the United States.

The proposed rule would also amend 27 CFR 447.52(b) to remove the list of former Soviet countries (Georgia, Kazakhstan, Kyrgyzstan, Moldova, Turkmenistan, Ukraine, and Uzbekistan) from which ATF currently denies applications to permanently import most firearms and ammunition, leaving only the Russian Federation as the proscribed country of origin subject to the mandatory denial. Comments are due July 6, 2026.

If finalized, importers of firearms and ammunition from countries other than Russia that were previously listed in 27 CFR 447.52(b) will be able to submit import applications, opening new sourcing opportunities for firearms and ammunition that are in high demand.

2. Adding component definitions under the Arms Export Control Act

ATF proposes to add definitions for “component,” “accessories and attachments,” and “part” to its AECA regulations at 27 CFR part 447, aligning with the Department of State’s ITAR definitions at 22 CFR 120.45 and 120.46. The US Munitions Import List (USMIL) uses these compositional terms to describe defense articles but has not previously defined them. If finalized, the proposed rule would help importers interpret what commodities are subject to the import controls and enable ATF to define these terms consistently when approving or denying import applications. Comments are due July 6, 2026.

3. Export Control Reform: Conforming references to the Department of Commerce

ATF is amending its regulations, via a direct final rule, at 27 CFR parts 447 and 479 to add conforming references to the Department of Commerce. Following the Export Control Reform initiative, which went into effect March 2020, both the ITAR and the EAR now have requirements regarding the export and temporary import of commodities that are on the USMIL and controlled by ATF for permanent import purposes. For example, firearms described on the Commerce Control List that are also on the USMIL must comply with the temporary import entry clearance requirements specified in 15 CFR 758.10 (unless certain circumstances apply), and firearms described on the USML that are also on the USMIL are subject to the ITAR’s export authorization requirements. This direct final rule updates ATF’s regulatory provisions to reflect this split in authority, adding references to the Department of Commerce and the EAR alongside existing references to the Department of State and the ITAR. The rule will go into effect on July 6, 2026 unless significant adverse comments are received by June 5, 2026.

4. Importing training rounds

ATF proposes to clarify that certain training rounds 1) do not meet the definition of “ammunition” under the GCA and 2) are not regulated by the AECA. ATF’s prior position treated training rounds as ammunition because they contained cartridge cases, primers, bullets, or propellant powder, resulting in a general prohibition on their importation under the GCA. This proposed rule would add an exception to the definition of ammunition for certain training rounds, allowing persons to import them without completing an ATF Form 6, part I, or Form 6A as the specified training rounds are not designed for use in any firearm. (Instead, the training rounds are designed to be fired from specially adapted training guns.) Less-than-lethal ammunition, which is distinct from training rounds, would still generally be considered ammunition. Comments are due August 4, 2026.

5. Converting temporary to permanent imports for defense articles

ATF proposes to allow importers to apply for ATF authorization to convert items originally imported temporarily – whether under Department of State ITAR authorization or under Department of Commerce EAR entry clearance requirements (15 CFR 758.10) – to permanent imports without needing to export and re-import the items. Under current regulations and ATF rulings, the only options for items imported temporarily are to export them or destroy them before the temporary authorization expires. (Such authorizations are generally valid for four years.) The inability to convert temporarily imported items to permanent imports has historically been a financially costly problem for industry. To remedy this problem, the proposed rule would amend the definition of “Import or importation” in 27 CFR 447.11, add a new conversion process at 27 CFR 447.42(c), and establish marking requirements for converted items at 27 CFR 478.112(e). Comments are due August 6, 2026.

If finalized, industry would have a defined process for converting items initially imported temporarily into lawful permanent imports without incurring expenses associated with destroying or exporting and re-importing the items.

6. Importing dual-use frames, receivers, or barrels

ATF proposes to clarify that 1) a frame, receiver, or barrel may be lawfully imported if, at the time of import, there is an identified firearm sporting configuration for the frame, receiver, or barrel, regardless of whether that frame, receiver, or barrel had been previously configured on non-sporting, military surplus, or NFA firearms and 2) a frame, receiver, or barrel that is imported because there is an identified firearm sporting configuration at the time of importation may be used to assemble a sporting, non-sporting, or NFA firearm, provided that assembling such firearm complies with 18 U.S.C. 922(r) and the NFA, 26 U.S.C. chapter 53, as applicable. Of note, this rule would codify ATF Ruling 2025-1 (which addressed only dual-use barrels) and extend the same analysis to frames and receivers. Comments are due August 6, 2026.

7. Removing triplicate filing requirement for importing plastic explosives

ATF will remove from 27 CFR 555.183 the requirement that importers of plastic explosives submit their required written attestation in triplicate when filing a Form 6, part I application. ATF previously required Form 6, part I applications to be submitted in triplicate, but, as ATF has modernized its processing systems and moved to electronic submission through its eForms platform, additional copies are no longer needed. This is a procedural housekeeping change that does not alter substantive requirements. This final rule is effective June 5, 2026.

8. Firearm activities in foreign trade zones and customs-bonded warehouses

ATF proposes to amend the definition of “importation” in its GCA and NFA regulations (27 CFR 478.11 and 479.11) to 1) extend the existing exclusion from import requirements for items brought into foreign-trade zones (FTZs) to also cover items brought into customs-bonded warehouses (CBWs) and 2) remove the condition that items may be brought into FTZs and CBWs only “for storage.” ATF explained that this proposed rule is in response to the results of ATF’s October 2024 open letter clarifying that the FTZ exemption did not extend to CBWs, which resulted in some industry members being forced to transition operations from CBWs to FTZs at significant cost. Comments are due August 6, 2026.

Conclusion

Taken together, these eight actions represent a substantial overhaul of ATF’s import regulations. Collectively, they signal ATF’s aim to modernize its import regulations, reduce compliance burdens on the firearms and defense industry, and align its regulations with those of the Departments of State and Commerce. In addition, these rulemakings present an opportunity for industry to engage with ATF regarding these reforms via the notice-and-comment process to provide feedback on proposed defense trade changes.

Learn more

For more information on these regulatory actions and their implications for businesses, including assistance with preparing public comments or assessing the impact of the proposed rules on defense trade operations, please contact the authors.