80% Lowers and the ATF Frame or Receiver Rule: FAQ
Updated October 30, 2026
What Did The ATF Do?
On August 24, 2022, the ATF’s Final Rule ( 2021R-05F), went into effect. This rule attempts to restrict the manufacturing, sale, and ownership of unfinished 80% lowers, 80% frames.
Under this rule, 80-Lower.com and other, similar businesses are restricted from selling some of our products to customers across the country.
Attempts to Restrict 80% Lowers
In the ATF’s Final Rule are new restrictions on AR-15 receivers. The rule attempts to redefine both upper and lower receivers as firearms. It also placed restrictions on unfinished 80% lowers.
Attempts to Restrict 80% Frames
Also contained in the Final Rule are new restrictions on unfinished handgun frames, like Polymer80 frames. This is an attempt to restrict the sale, ownership, and use of Polymer80 and other 80% frames to make a firearm.
What Happened To The Rule?
On June 30th, 2023, a federal court vacated the ATF’s Final Rule. This eliminated the restrictions the ATF put in place in 2022 and prevented the government from restricting firearm parts like 80% lowers and 80% frames.
Since then the ATF has asked the district court for a stay. The court offered a temporary stay and then ultimately the 5th Circuit Court of Appeals denied the federal governments attempt to completely stay the district court’s decision, which prevented the ATF from enforcing the rule’s “regulatory definitions of ‘frame or receiver’ and ‘firearm’ as it applied to the Gun Control Act of 1968.”
This was a big win for 80% lower buyers and sellers.
The government then asked the Supreme Court to fully stay the ruling, which would allow the rule to remain in effect while the lawsuit continued.
Unfortunately on August 8, 2023 the Supreme Court voted 5-4 for a stay, which allows the rule to go back into effect while the government appealed the district court’s judgment.
On November 9, 2023,the Fifth Circuit held that the rule exceeded ATF’s authority and upheld the district court’s decision to throw out the ATF “Frame or Receiver” Rule! It is important to note that while the case is still active the rule can be enforced due to the SCOTUS order which blocked the District Court ruling until the case is resolved..
On February 7, 2024 the DOJ filed a Cert Petition with SCOTUS in the VanderStok v Garland Lawsuit to review the judgement of the United States court of Appeals for the 5th Circuit.
On April 22, 2024, The United States Supreme Court agreed to review the case of Attorney General Merrick B. Garland v. Jennifer VanDerStok. This lawsuit, brought by the Firearms Policy Coalition (FPC) and FPC Action Foundation (FPCAF), challenges President Joe Biden’s ‘frame or receiver’ rule enacted by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The Supreme Court heard the case during its October 2024 term.
On March 26, 2025, the Supreme Court ruled 7-2 in Bondi v. VanDerStok that the rule is valid on its face under the Gun Control Act. The rule remains in effect.
What Has Happened Since?
In April 2026, the Justice Department and ATF told courts they plan to issue a new frame or receiver rule. As of this update, the new rule hasn’t been published, and the 2022 rule is still in effect.
On August 17, 2026, in Defense Distributed v. Blanche, the U.S. District Court for the Northern District of Texas held parts of the rule unconstitutional. Its order bars enforcement only against the plaintiffs and Second Amendment Foundation members, and only for specific products: certain M1911 80% frames and the G80 build kit, unfinished receiver and grip module. It does not change the rule for anyone else, and it may be appealed.
Can I buy 80% lowers and 80% frames?
Yes, where your state allows it, as long as the lower can’t be readily completed and isn’t sold with a jig or tooling. Under the rule, those would be treated as firearms.
80% frames are more restricted. Under the rule, most handgun frame kits are treated as firearms. ATF’s December 2022 open letter explains how it applies the rule to partially complete frames. The Defense Distributed decision above covers only certain products and buyers, so check the details before you buy.
Please note, however, that your state may have passed laws restricting or banning these products. Before ordering, check our Shipping & Return Policy to ensure you do not live in a restricted state.
What can I do to help out?
Please continue supporting small businesses like us by continuing to shop with us.
Support 2A foundations such as the Firearms Policy Coalition (we are a proud Alliance Member), Gun Owners of America, and Second Amendment Foundation.
Stay vigilant in being aware of local and federal laws on the brink. Be active in contacting your local Senate and Congress representatives.
This FAQ is general information, not legal advice. Federal rules for frames and receivers are changing, and state and local laws vary. Check current ATF guidance and your state’s laws before you buy or build.
