Airguns as Firearms: What Garrett's Law Means for FFLs

Read this before you change anything

On September 24, Rep. Kevin Mullin (D-CA-15) introduced H.R. 10583, “Garrett’s Law” — a bill to amend chapter 44 of title 18 so that high-powered airguns are treated as firearms under federal law. It was referred to the House Judiciary Committee and has not moved since. Nothing in your store changes today, and the odds against any individual bill are long. But it is worth twenty minutes of a dealer’s attention, because the category it targets sits on a lot of shelves, and because the draft gives the industry an unusually long runway: the classification would take effect 850 days after enactment, with the Attorney General allowed up to 365 days to publish compliance guidance.

Strip the politics out and three questions are left: what is your airgun inventory worth, what does your margin look like if the channel changes, and where do you want to sit in that channel. Those are questions you can answer this quarter.

What the bill would actually do

Garrett’s Law would designate “lethal air guns” as firearms under the Gun Control Act. The draft sets velocity and caliber thresholds. An airgun is captured if it fires:

• a .177-caliber pellet at 800 feet per second or more,
• a .22-caliber pellet at 500 fps or more,
• a .25-caliber pellet at 450 fps or more, or
• any metallic pellet larger than .25 caliber.

The Attorney General could add other airguns by rulemaking. The sponsor’s release says paintball guns and non-lethal airsoft guns are excluded.

If that definition survives the legislative process, covered airguns become firearms for federal purposes: manufacturers and sellers would need federal licenses, serialization and recordkeeping requirements would apply, and retail sales would run through the same background-check process as everything else behind your counter. The bill is endorsed by GIFFORDS and March For Our Lives and opposed by the Citizens Committee for the Right to Keep and Bear Arms, which calls the airgun reclassification an overreach.

One detail matters more than the politics for planning purposes: these thresholds are not exotic. A large share of mainstream .177 pellet rifles — break-barrels, gas-piston guns and multi-pump models sold as youth and varmint guns — are rated at 800 fps or above. This would not be a bill about exotic big-bore hunting airguns only. Read the thresholds as a category-wide line, not a specialty line.

Three kinds of seller, three very different outcomes

Online-only and big-box airgun sellers. For a business built on shipping airguns direct, licensing, serialization and background checks are close to existential. Some will get licensed. Some will exit the category. Either way, the direct-to-consumer pipe narrows.

Licensed dealers who already stock airguns as a sideline. The lift is smaller than it looks. You hold the FFL. You keep a bound book. You already run 4473s and NICS checks all day. A new SKU class inside an existing compliance process is an operations problem, not a rebuild.

Dealers with no airguns today. The opportunity is not the product. It is the service gap that opens if direct shipments have to route through a licensed local dealer.

The revenue line to think about: the transfer desk, again

Every category restriction the industry has absorbed over the last decade has ended in the same place. Buyers still want the product, and the logistics route through a local FFL. That is the transfer-desk playbook, and airguns are a plausible next candidate. High-velocity PCP rifles and big-bore airguns are high-ticket items with a national buyer base that today buys direct and never sets foot in a store.

The relevant question is coverage. Texas lists 8,328 licensed dealers. California lists 2,063. But among those thousands, almost nobody advertises airgun transfers, sells fill tanks and pellets alongside them, or has a staff member who can explain the difference between a regulated and unregulated airgun. That is either an open niche or evidence the demand is not there — and the way to find out is to ask your customers and your distributor rep, not to guess.

What makes the category attractive on paper is the attach rate. A transfer brings in a fee, then pellets, optics, cases, cleaning gear and fill service, and the buyer who learns to trust your counter comes back. Transfer-heavy categories are also the cheapest customer acquisition you have: the customer arrives with the transaction already in hand.

A 90-day prep list that costs almost nothing

1. Audit your air SKUs against the thresholds. Build a simple sheet: brand, caliber, rated muzzle velocity, units sold per quarter, average margin. You will learn quickly whether this is a $2,000 category or a $200,000 one, and the answer determines how much of this article matters to you.
2. Ask your distributors for a compliance read. The importers and wholesalers carrying air lines are modeling this already. Ask what they expect on serialization, packaging and how they would handle dealer-direct shipments.
3. Model the margin, not the volume. If airguns become transfer items, your revenue changes shape: less product margin, more service and accessory revenue, more customer visits. Run that version of the P&L before you decide whether to lean in or lean out.
4. Claim the local position if you want it. That means a landing page, a service entry on your Google Business Profile, and an FAQ that answers “will you accept an airgun transfer?” Buyers search metro by metro — the Houston dealer page shows the format buyers already land on. It is the same local-search work as any other transfer category.
5. Do not panic-buy and do not dump. An 850-day runway makes liquidation the wrong move, and killing a growing category to dodge a bill that may die in committee is how dealers leave money on the table.
6. Brief your staff on what the bill says, not what it does. “A bill was introduced” is accurate. “Airguns are firearms now” is false, and it is the kind of false that turns into a customer complaint or a bad counter conversation.

What hasn’t happened yet

A bill being introduced is not a rule. Most introduced bills die in committee, and this one has no hearing scheduled, no companion in the Senate and a sponsor in the minority. Dealers who reorganize their business around the introduction of a bill are making the same mistake as dealers who ignored the last five compliance changes the industry actually absorbed. Watch for two markers that would move this from news to planning: a committee hearing, and a companion bill in the Senate. Until then, treat it as a category signal, not a deadline.

The other recordkeeping story this week

Separately, Rep. Michael Cloud (R-TX) sent a September 29 letter to President Trump and Vice President Vance — signed by 23 other House members — arguing that the ATF’s holdings of 1,414,088,513 firearm transaction records at its Martinsburg, West Virginia facility, largely collected from out-of-business dealers and roughly a billion of them digitized, amount to an illegal national registry under the Firearms Owners’ Protection Act of 1986. ATF’s position is that the Out of Business Records system cannot be searched by name or other personally identifiable information, even though the records contain it. No dealer obligation follows from the dispute. It is filed away here for one reason: the records you hand over when you close your doors have a very long afterlife, and recordkeeping is the piece of the ATF relationship most likely to be re-litigated. Dealers who keep clean, complete and accurate books are exposed to less of it, whoever wins the argument.

The takeaway

Garrett’s Law is not a compliance problem this quarter. It is a category question with an unusually generous clock attached: 850 days after enactment, and no enactment yet. Use that time to know what your airgun shelf is worth, what it would be worth as a transfer and accessory category, and whether you want to be the shop in your market that answers the phone when a buyer with an inbound PCP rifle calls. Growth in this business usually comes from being early to a category that someone else is about to regulate — and from keeping the books that let you survive the parts of this industry that do not go your way.