The Bureau of Alcohol, Tobacco, Firearms and Explosives has informed plaintiffs in the ongoing VanDerStok v. Bondi litigation that it will not draft a new frames-and-receivers rule, reversing an earlier position that surprised many in the industry, according to AmmoLand News. Just weeks earlier, the Department of Justice had requested a 90-day stay of proceedings in the case, explicitly citing plans to promulgate a replacement regulation that might resolve or moot some of the plaintiffs' remaining constitutional claims — suggesting to plaintiffs and industry observers alike that a rewrite was imminent.
The rule at issue — Final Rule 2021R-05F, the Biden administration's 2022 frames-and-receivers regulation — expanded ATF's definitions of "firearm," "frame," and "receiver" under the Gun Control Act, classifying a broad range of partially completed lower receivers as regulated firearms subject to serialization requirements and background-check transfer rules. The Supreme Court upheld the rule's core framework 7–2 in Bondi v. VanDerStok last year, finding it consistent with the Gun Control Act's text and rejecting the facial challenge. That decision left as-applied constitutional challenges intact, which remain the focus of continuing litigation.
Sources close to the case told AmmoLand that internal DOJ reviews concluded a full rewrite would introduce fresh legal complications rather than resolve the existing ones — particularly in light of the Supreme Court's recent endorsement of the 2022 framework. The Firearms Policy Coalition, a plaintiff in VanDerStok, and the Second Amendment Foundation, active in related litigation, described the reversal as "a betrayal of the review process" and confirmed they would continue pressing constitutional and as-applied challenges. A companion proceeding, Defense Distributed v. Bondi, also remains active.
For lawful manufacturers, 80-percent receiver retailers, and home builders, the compliance picture is unchanged: receivers that fall within ATF's expanded definition are regulated firearms, serialization requirements apply, and transfers must go through federal licensees. The ATF had separately announced a new era of reform centered on greater transparency and partnership with the licensed industry — but that initiative has not, at least for now, extended to the 2022 frames-and-receivers framework.
The FPC's Fifth Circuit challenge is the most immediate avenue for a further rollback, with oral argument scheduled for May. Watch for pre-argument motions and any injunctive orders from the Fifth Circuit in the weeks ahead as plaintiffs weigh their options.



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