CRPA Submits Comments on DOJ’s Proposed Regulations Regarding “Self-Manufactured or Self-Assembled Firearms”

November 19, 2019

With the adoption of SB 746 in 2018, any person moving into the state of California with a home-built firearm must now, within 60-days of arrival, obtain and engrave a DOJ-approved serial number on their firearm. In connection with this new requirement, DOJ has proposed several regulatory changes to its existing “Unique Serial Number Application Process.” Today, CRPA attorneys, with the support of NRA, filed a comprehensive comment letter on those proposed changes.


As discussed in CRPA’s comment letter, DOJ’s proposal conflicts with existing federal regulations and otherwise fails to meet the required necessity, authority, consistency, and clarity requirements of California’s Administrative Procedures Act (“APA”), which all regulatory proposals follow. Specifically, DOJ’s regulations improperly access the National Instant Criminal Background Check System, fails to adequately define the term “receiver or frame, unfinished,” and improperly prohibits the issuance of a unique serial number to those persons whose background check results in an “undetermined” status.


CRPA members should also be aware that there is still time to submit additional comments on DOJ’s proposed regulations should they choose to do so. Any comments must be submitted by 5:00 PM today to the following:


Kamran Ali

Bureau of Firearms

Division of Law Enforcement

Department of Justice

P.O. Box 160487

Sacramento, CA 95816-0487


(916) 227-5419


To keep informed on this and other regulatory proposals, as well as important Second Amendment related news in California, be sure to subscribe to CRPA email alerts at www.CRPA.org.

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