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ATF Importation Form 6 Exemption for Benelli M4


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So I have been doing more digging into the ATF Form 6 exemptions.  I have previously thought I understood the terms.

I've been under the understanding that a form 6 exemption is granted for Benelli M4 accessories and parts that are $100 and less, under point 4, sub section 3 which reads:

  • “Minor components and parts for Category I(a) and I(b) firearms except barrels, cylinders, receivers (frames) or complete breech mechanisms, when the total value does not exceed $100 wholesale in any single transaction.”

Under Category I(a) and I(b) firearms it states the following:

  • a. Nonautomatic and semiautomatic firearms, to caliber .50 inclusive, combat shotguns, and shotguns with barrels less than 18 inches in length, and all components and parts for such firearms.

I have always assumed that the Benelli M4 was considered a combat shotgun, however, with further digging I have learned that the ATF classification for the Benelli M4 is a "Sporting Shotgun" as it is imported into the USA with the standard stock and magazine limiter installed.  So every Benelli M4 that is imported into USA and sold to civilians is a "sporting shotgun" and not a "Combat Shotgun".

This lead me to read further down the Form 6 Exemptions list, point 6 which reads: 

  • Sporting shotgun parts other than firearm frames or receivers or barrels. [are exempt from Form 6]


So, what I take away from this is that all parts and accessories that are imported into the USA (from Canada for example) for the Benelli M4, which is a sporting shotgun, are exempt from filing a Form 6, regardless of the dollar value for the purchase (of the parts or accessories).

Is there any reason to think that this line of thought is incorrect?

Edited by RxArms
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