When is a firearm considered imported for purposes of calculating the 15-day period within which an imported firearm must be marked and reported to ATF on Form 6A?
A firearm (as well as ammunition and other defense articles) is imported on the day it is released from the custody of U.S. Customs and Border Protection (CBP) and brought into the United States, which may be different from the day it is physically received by the importer. The date of import is based on the Gun Control Act’s regulatory definition of importation in 27 CFR 478.11. The permissible period of time within which importers must comply with applicable marking and recordkeeping requirements is calculated using the date of importation as the starting point. See related August 27, 2010, Open Letter posted on the ATF website.
