Rare Breed Trigger’s ATF Response

According to recoilweb

In the last few months, we have seen a dramatic uptick in the presence of the ATF in the eyes of the public. From the struggling nomination of David Chipman for the position of Director, to the attempt to redefine what is considered a receiver for the sake of regulation, to the current reclassification of Pistol Stabilizing Braces as criteria for considering a firearm an SBR, these events have drawn the attention of our firearms culture. As the bump stock ban from the previous administration faces more and more challenges, the ATF has sent a cease-and-desist letter to Rare Breed Triggers, regarding the manufacturing of the FRT-15. In cases like this, we often sink into a familiar pattern: the articles are written, attention gathered, with most of the work being done outside of the public’s eye. The Rare Breed Triggers ATF Response, however, sings a different tune.

The FRT-15 is one example of why definitions matter, and why there must be a partition between the person who interprets a law, and the one who enforces it. The FRT-15 is a drop-in trigger replacement for AR-15 style rifles that utilizes a mechanism to force the reset of the trigger. This is where it gets its name, as the Forced Reset Trigger, and the result is the ability for a disciplined trigger finger to fire quickly, too quickly it seems, for the ATF to let it go. As a result, Rare Breed Triggers received a Cease and Desist letter from the ATF, who claimed that the FRT-15 was determined to be a Machine gun, and subject to regulations accordingly.

Much like language, the law fails to govern successfully when definitions are not followed or can be arbitrarily ignored by enforcing agencies out of expediency. So when the ATF is given a working definition for a machine gun, and then claims that something which does not fit within that definition is now considered to be one, not only does the integrity of the law suffer, but the safety and well being of the people.


A machine gun is defined by the National Firearms Act 26 U.S.C. 5845(b) as any combination of parts designed and intended for use in converting a weapon to shoot automatically more than one shot, without manual reloading, by a single function of the trigger.

This working definition is used in such a way to identify items that in and of themselves, could not possibly meet the definition of a machinegun, much less a firearm: a trigger or bump stock does not itself have a barrel and cannot expel a projectile through the expansion of gasses in a contained chamber. The FRT-15 does not fit the definition presented either, but appears to be considered a machine gun simply because the ATF cannot tell the difference when someone is using it. If this were allowed to be the standard, then illiteracy would be the highest form of virtue.

The crux of the definition rests on the human input: one round fired per function of the trigger. There is a difference between being able to pull the trigger quickly, and simply hold it down. What the Rare Breed Triggers FRT-15 does is mechanically reset the trigger, while preventing the hammer to drop until the bolt is locked into the chamber. What it does not do is allow the hammer to drop without the trigger being pulled again by the wielder. One function of the trigger: one shot fired.

When Rare Breed Triggers received a cease-and-desist order from the ATF, it included an additional requirement for the manufacturer to contact the ATF and establish a plan of what to do with the FRT-15 triggers that had already been sold. The authority of the ATF has been challenged in the past, and so when Rare Breed Triggers gave their response, it wasn’t without some recognition of what could happen next.

rare breed triggers ATF response letter

Instead of capitulating to the ATF’s claim that the FRT-15 was a machinegun, and worse, diverting their efforts as private citizens to do the bidding of a Government Agency, they responded publicly stating their non-compliance, and backing it up with legal opinion. Christopher Gadsden would be proud.

Rare Breed Triggers simply said no, arguing that the FRT-15 clearly and deliberately does not fulfill the definition of a machine gun, and thus is not subject to regulation by the ATF. As a result, Rare Breed continues to manufacture the FRT-15, and is making no plans to attempt to recover triggers purchased by them. At the time of writing, there is no news regarding how the ATF will react to Rare Breed Trigger’s response.

The challenge with this type of action by the ATF is that the result of redefinitions, reclassifications, and overt over-stepping of the limitations to their authority does not go without disturbing law-abiding American Citizens. Instead of focusing on the actions of those who wish to harm the American people, instead of directing efforts to enforce the laws that govern, these actions would make felons of other-wise innocent people. The possession of things like bump stocks, pistol braces, 80 percent receivers, and forced reset triggers, if prohibited, would produce only victimless crimes.

Which draws attention to the ATF as at least suspicious in the eyes of so much of the American people, as the agency continues to act in such a way that at least looks like they are more interested in infringing on the rights of free people, than protecting said rights.