Bulletin 25-02
REFERENCE: Firearms Manufacturers Offering Gunsmithing Services Within the Scope of a Type 07 Federal Firearms License
June 6, 2025
The definition of “Dealer” in state statute and rule is tied to the specific type of Federal Firearms License (“FFL”) held by a business or individual.
Under state law, beginning July 1, 2025, firearm dealers in Colorado are required to hold a valid State Firearms Dealer Permit (“State Permit”) to sell firearms other than destructive devices to the public in this state.
Specifically, the statutory definition of “Dealer” is applicable to:
- All Type 01 (Dealers in Firearms other than destructive devices (including Gunsmiths)) and Type 02 (Pawnbroker in Firearms other than destructive devices) FFL holders; and
- Any Type 07 (Manufacturers of Firearms other than destructive devices) and Type 08 (Importers of firearms other than destructive devices) FFL holders who, within the scope of their FFL, sell firearms at retail to the public.
Therefore, a Type 07 Firearms Manufacturer that does not sell firearms at retail to the public within the scope of their federal firearms license is not required to obtain a State Permit, as they are not considered a “Dealer” under the applicable state law and regulations. See section 18-12-401(1), C.R.S., and Rule 1-110.
In accordance with these statutory and regulatory provisions, the Firearms Dealer Division has determined that a Type 07 (manufacturer) FFL that provides gunsmithing-type services is only required to obtain a state permit if their business activities include selling firearms at retail to the public.
For further information and application details, please visit https://sbg.colorado.gov/
Firearms Dealer Division
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