This is in reply to your letter dated January 15, 2000, in which you seek clarification of previous correspondence from
this office regarding replacement parts for large capacity ammunition feeding devices.
You specifically ask about sending magazines that were lawfully possessed prior to the enactment of the Violent Crime
Control and Law Enforcement Act of 1994, back to respective manufacturer's to be refurbished. The cited act was
enacted on September 13, 1994.
The Bureau of Alcohol, Tobacco and Firearms has advised that individual component parts of a large capacity
ammunition feeding device, i.e., follower, spring, magazine body, and baseplate, in and of themselves do not
constitute a large capacity feeding device. The above individual parts, irrespective of their date of manufacture, may be
used or sold, as replacement parts for lawfully possessed large capacity magazines. We would point out that the
transfer of sufficient component parts in piecemeal fashion to assemble a large capacity magazine, would be treated
as the transfer of a restricted magazine. An existing pre-ban magazine may not be exchanged for a magazine
manufactured after September 13, 1994. Further, such a transfer may also constitute unlawful aiding and abetting the
purchaser's violation of possessing a large capacity magazine. Therefore, all components can be replaced, but cannot
be done on the same occasion.
We trust that the foregoing has been responsive to your inquiry. If we can be of any further assistance, please contact
us.
Sincerely yours,
Edward M. Owen, Jr.
Chief, Firearms Technology Branch
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