The End of SSE, or Am I Trippin?

[gorgothmog]

Anybody take a hard look at AB 1263's specific language surrounding what manufacturing means?

Taking a closer look at the text for AB 1263 (effective Jan 1, 2026), and it looks like the specific wording closes the SSE conversion loop by killing the "subtraction isn't manufacturing" argument.

PC 29186(a)(6) makes it a specific misdemeanor (w/ 10-year ban) to "manufacture" an "Unsafe Handgun" (off-roster semi-auto).

PC 29180(a) explicitly defines "manufacturing" to include "subtractive" processes.

Pulling the sled/inner barrel (subtraction) from a compliant SSE pistol is now codified as "manufacturing." Since the result is an off-roster semi-auto ("Unsafe Handgun"), the act of removing that part triggers the new PC 29186 prohibition.

The "it’s just a modification" defense seems to be on shakey ground under these definitions. Thoughts?

 

[Hit Factor]

Anybody take a hard look at AB 1263's specific language surrounding what manufacturing means?

Taking a closer look at the text for AB 1263 (effective Jan 1, 2026), and it looks like the specific wording closes the SSE conversion loop by killing the "subtraction isn't manufacturing" argument.

PC 29186(a)(6) makes it a specific misdemeanor (w/ 10-year ban) to "manufacture" an "Unsafe Handgun" (off-roster semi-auto).

PC 29180(a) explicitly defines "manufacturing" to include "subtractive" processes.

Pulling the sled/inner barrel (subtraction) from a compliant SSE pistol is now codified as "manufacturing." Since the result is an off-roster semi-auto ("Unsafe Handgun"), the act of removing that part triggers the new PC 29186 prohibition.

The "it’s just a modification" defense seems to be on shakey ground under these definitions. Thoughts?

You’re trippin’.

 

[Deleted member 16735]

Anybody take a hard look at AB 1263's specific language surrounding what manufacturing means?

Taking a closer look at the text for AB 1263 (effective Jan 1, 2026), and it looks like the specific wording closes the SSE conversion loop by killing the "subtraction isn't manufacturing" argument.

PC 29186(a)(6) makes it a specific misdemeanor (w/ 10-year ban) to "manufacture" an "Unsafe Handgun" (off-roster semi-auto).

PC 29180(a) explicitly defines "manufacturing" to include "subtractive" processes.

Pulling the sled/inner barrel (subtraction) from a compliant SSE pistol is now codified as "manufacturing." Since the result is an off-roster semi-auto ("Unsafe Handgun"), the act of removing that part triggers the new PC 29186 prohibition.

The "it’s just a modification" defense seems to be on shakey ground under these definitions. Thoughts?

I was looking at that, it's hard to tell because does it count as "manufacturing" if it is already a firearm? The manufacturing occurs when the firearm registers it's serial number with the feds, historically. Also the roster only applies to dealers so conversion done by the owner has historically been under a different category. It's very unclear what these new laws will ultimately cover.

 

[gorgothmog]

You’re trippin’.
View attachment 119530

Thank you for that. That's VERY helpful, and puts my worst fears to bed, lol. I appreciate you looking into it.

 

[RickD427]

I was looking at that, it's hard to tell because does it count as "manufacturing" if it is already a firearm? The manufacturing occurs when the firearm registers it's serial number with the feds, historically. Also the roster only applies to dealers so conversion done by the owner has historically been under a different category. It's very unclear what these new laws will ultimately cover.

That argument went out of the window with Broughman v Carver...

 

[exnds]

That argument went out of the window with Broughman v Carver...

So Rick are you telling us beginning 1/1/2026, no more SSE 2011s coming to California?

 

[Deleted member 16735]

That argument went out of the window with Broughman v Carver...

From the case opinion" Under the GCA, a firearms “manufacturer” is defined as “any person engaged in the business of manufacturing firearms or ammunition for purposes of sale or distribution.” under that definition an individual is not a manufacturer and conversion wouldn't count as manufacturing would it? These are also different laws though, the GCA is federal and we are dealing with new laws and circumstances that may not be related as the new CA laws clearly are talking about individuals manufacturing firearms for themselves.

 

[RickD427]

So Rick are you telling us beginning 1/1/2026, no more SSE 2011s coming to California?

Please see my response to Mr. MrMister below. The short answer is nobody really knows as of yet.

 

[adrkwan]

Thank you for that. That's VERY helpful, and puts my worst fears to bed, lol. I appreciate you looking into it.

"CNC milling machines use subtractive manufacturing: essentially breaking down a raw material until the desired product is created. 3-D printers, by contrast, use an additive manufacturing process that lays down consecutive layers of material to generate various products."

https://sjud.senate.ca.gov/system/files/2025-07/ab-1263-gipson-sjud-analysis.pdf

 

[RickD427]

From the case opinion" Under the GCA, a firearms “manufacturer” is defined as “any person engaged in the business of manufacturing firearms or ammunition for purposes of sale or distribution.” under that definition an individual is not a manufacturer and conversion wouldn't count as manufacturing would it? These are also different laws though, the GCA is federal and we are dealing with new laws and circumstances that may not be related.

You're correct in the limited view that you gave above. But the situation is a lot more complex, and Californians do have a lot to be concerned with resulting from the Broughman decision.

We first should understand that Broughman was a Fourth Circuit federal decision, and, as such is not directly binding on state and federal courts within California. What Broughman decision did was to end the argument that once a firearm was manufactured (and assigned a serial number), that any subsequent changes to it could not be considered as "manufacturing". The belief that a firearm could only be manufactured once went out the window. Mr. Broughman held a Dealer FFL. He purchased firearms that had already been manufactured and assigned serial numbers using his FFL. He then customized the weapons for sale to his customers. The court held that his performing the customizing work on the already-manufactured firearms was an act of manufacturing and that a Manufacturers FFL was required. Significant to the Broughman decision was Mr. Broughman's activities were in preparation for the first retail sale of the weapons.

The California DOJ has taken the position, apparently derived from Broughman's reasoning, that making certain changes to an already manufactured (and registered) Assault Weapon was an act of "Manufacture." This is in regard to the removal of the "Bullet Button" from a Registered Assault Weapon, thereby making a "new" Assault Weapon (refer to 11 CCR 5477).

The danger for Californians is that Broughman provided a definition of "Manufacturing" that included the making of changes to an already manufactured firearm. California has not defined the term "Manufacturing" in the Penal Code, and has not, to my knowledge, defined the term with regard to firearms in any published case decision. That leaves a California court free to look for an authoritative definition. When confronted with such choices, courts tend to first look to published case law. That takes us straight to Broughman. I have to think that was the analysis taken by our DOJ attorneys when they drafted the text of 11 CCR 5477.

California law makes many provisions about the "manufacture" of firearms. Broughman seems to give the most authoritative definition to what that word means. Without having a better source of an authoritative definition, Broughman should cause some concern.