ATF Q&A: A&D Books

The column heading “Manufacturer and/or Importer” has long been a bit of a misnomer.  Since the publication of the 2014 edition of the ATF “Federal Firearms Regulations Reference Guide” (the white book), ATF has officially modified the table that shows the required format of A&D records to change that heading to, “Manufacturer and Importer (if any)”.  Both the name of the foreign manufacturer and the name of the U.S. importer have been required in the A&D records since the regulations were written, but the example table showed that somewhat misleading column label in the regulations.  If a firearm is manufactured outside the United States and imported into the United States, both the foreign manufacturer’s name and the U.S. importer’s name must be shown in the A&D records.  That information is required to be engraved on the firearm, and FFLs should get that information from physically examining every firearm.  (NOTE:  While there is a minor exception to this requirement in the instructions for block 24 of ATF Form 4473, we recommend that the A&D description and the Form 4473 Section D description be identical for every firearm.  There is no valid reason for them to be different.)”