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Proposed Amendments to the Firearm Safety Device Regulations under Title 11

CRPA ALERT

The California Department of Justice has published proposed amendments to the Firearm Safety Device (FSD) regulations under Title 11, Division 5, Chapter 6 of the California Code of Regulations. These proposed changes affect firearm dealers and FSD/firearm manufacturers. Key provisions are summarized below.

 

Changes Affecting Firearm Dealers

 

  • Updated lock box affidavit requirements: Purchaser affidavits must now include the manufacturer name, model number, and model name (replacing the prior “make and model” language), along with a statement that the lock box can accommodate the specific firearm(s) being purchased. Dealers should update intake forms and checklists accordingly.
  • Expanded recordkeeping: Dealers must retain all “documentation and affidavit” (broadened from “statement(s)”) provided by the purchaser for three years alongside the DROS. Review your current retention practices to confirm compliance.
  • Delisted lock boxes: A lock box removed from the Roster solely because the manufacturer failed to timely renew may still satisfy the FSD requirement. Be careful not to reject a valid lock box at point of sale under these circumstances.

 

Changes Affecting FSD and Firearm Manufacturers

 

  • Permanent marking standards clarified: Manufacturer name, model number, and model name must be stamped, etched, molded, or otherwise durably marked on a permanently attached part of the device and designed to last the expected lifetime of the equipment. Evaluate your current labeling methods against these specifications.
  • Annual renewal certification required: FSD manufacturers must submit a renewal request by the first business day of each calendar year, reporting whether the model has been modified and describing any changes. The certification must be signed under penalty of perjury.
  • Strict removal deadline: If DOJ does not receive the renewal by February 28, the device will be removed from the Roster, and DOJ may destroy any prototypes in its possession. Reinstatement after removal requires going through the full approval process under Penal Code §§ 23655 or 23658.
  • DOJ discretion on near-miss devices: If an FSD meets all Roster requirements except permanent marking (PC § 23655(f)(2)), DOJ may require the manufacturer to redesign and resubmit rather than issue an outright denial.
  • Expanded statutory authority: The regulations now reference Penal Code § 23658 alongside § 23655 throughout, covering FSDs listed without laboratory testing. Manufacturers relying on the § 23658 pathway should confirm their devices comply with these updated provisions.

 

Submit Public Comments by September 15, 2026

CRPA members and other interested parties may submit written comments on the proposed regulations before 5:00 p.m. on September 15, 2026, using either of the following methods:

 

 

We encourage CRPA members to review these proposed changes against current compliance procedures and to submit comments where the regulations may impact your operations. The full text of the proposed regulations is available on the DOJ Firearm Safety Device Regulations page