A Sad Update For The Tenko 10-16

[A&S Conversions]

We just received a letter from the Firearms and Ammunition Technology Branch dated February 1, 2019. The FATD is returning the Tenko 10-16 adapter without a determination. We were notified by both Sam and another SOT that has done work for us back on December 10, 2018 that the FATD would no longer make determinations for the industry on accessories without out the complete firearm. The email and the notice on the website were specific to the industry. Well apparently that is also for private individuals. We will be shipping a complete Tenko 10-16 system including a transferable M10 RR to the FATD ASAP. Our 120 days for the determination would have been at the end of this month. Now that is out the window. We can only assume that the 120 days for the determination of the aluminum version will be reset to start when the FATD receives the complete adapter system with the transferable M10 RR.

Scott
Manager A&S Conversions L.L.C.

 

[john-g]

At least it wasn't a no right?
So, you just need to send a post sample in with the Tenko for testing?

 

[har1340]

Cork soakers.

 

[llamasabound]

I opened this link with a heavy heart. What a relief to read the contents. This isn’t a sad update — this is a to-be-expected delay. A sad update would be a determination that the adapter constitutes a firearm on its own.

Hoping the shipping is swift and trouble free, and that FATD process is as straightforward as can be.

 

[root]

Ya really I was thinking doom and gloom as in it was shot down and a no go.

We all kinda expected the kick back without the RR lower on it.

What's another 120 days since all it is a resubmit as a complete firearm instead of parts.

I also think this new "complete setup" is mainly due to the whole bump stock fiasco.

Good luck with the submission I hope it all goes smooth and approved.

I already have a few parts kits and possibly a gun ready to be sold when they start shipping.

Best of luck with this I don't just mean that because I want one ( I do and I'm # 76) but because I know you have so much more riding on their approval then most will ever realize.

Rich

 

[A&S Conversions]

At least it wasn't a no right?
So, you just need to send a post sample in with the Tenko for testing?

We are not SOT. I have no Post Sample to send. We will be shipping them a transferable. I am absolutely sure that the submission will be determined to be an accessory. We shipped them basically an aluminum version with captured pins compared to the 3D printed proof of concept version with bolts and push pin. It just pisses me off as the 120 days would have been at the end of this month. My guess is it came to the top of the pile, they opened the box, noticed that there wasn't a complete firearm and sent the letter. The adapter should show up this week. We will try to turn it around ASAP. Hopefully it will be like a problem with the Form, we won't loose our place in line.

Scott
Manager A&S Conversions L.L.C.

 

[YourCoWorker]

You have a real winner on your hands and you will get thru the review process. Keep pushing - 120 more days sucks, but think of the long game - it's absolutely worth it.

 

[Mackjack]

120 days to get the m11/9 version ready!? Right?

 

[rentprop1]

Does thos not work with a semi auto ? If so thats what you should be sending in, no ?

 

[thelastdinosaurs.com]

Stupid question. Isn't this version just an update from the original? If something goes wrong can't the original approved version be produced?

 

[Esox]

Not sad...just frustrating. Hopefully the Tenko gets put to the front of the line and approved quickly for you!

 

[stevo]

Better check with them on sending a transferable M-10 as you’re not an SOT. You will probably have to form 5 or some other form showing them as transferee....Not 100% sure when sending directly to ATF. Also make damn sure that they will return your Mac back to you...again, some form may be required.
Steve

 

[A&S Conversions]

120 days to get the m11/9 version ready!? Right?

This will certainly complicate the M11/NINE version. In perpetration of the M10 version I bought a couple of M10 RRs because of all the variations of M10s. Since there was only one M11/NINE manufacturer I thought I would only need one. If I send my only M11/NINE, I wouldn't have a M11/NINE to work with while waiting for the determination.

Does thos not work with a semi auto ? If so thats what you should be sending in, no ?

The Tenko adapter is for registered receiver machineguns. We had to design the adapter to work only with RR, not open bolt semiautomatic pistols.

Stupid question. Isn't this version just an update from the original? If something goes wrong can't the original approved version be produced?

Yes, that would be possible. I don't think that would be as practical. The original proof of concept was 3D printed from a nylon with a melting point of 360 degrees. That wouldn't be too bad for pistol caliber, but rifle calibers have much higher temperatures.

We will get through this process and bring the refined Tenko adapter to the market. Is this frustrating? Absolutely, but we are committed to bringing this adapter to market. Thank you for the support.

Scott
Manager A&S Conversions L.L.C.

 

[MACchat]

Wouldn’t it make sense, at this point, to just get a SOT?

 

[A&S Conversions]

It is part of the plan, but not right now. It would be possible to do so, but that is not an overnight proposition. It will take three to four months to do so. We can't make a Post Sample until we have the the paperwork in hand. I have a couple of original flats. I could bend and weld them, but I don't know as I have the skills to finish them properly. So off to Sam for finishing. That could all take six months. Then the adapter still needs to be submitted. I don't want to wait a year to bring the Tenko to market.

I think the most expedient route is to ship one of our transferable M10 RRs. I don't want to, but the Post Sample route would take three or four times as long.

Scott
Manager A&S Conversions L.L.C.

 

[TSPC]

Just out of curiosity, is a determination letter mandatory for a product like this? I understand why you would want one and refuse to manufacture or sell without one and am not suggesting you do otherwise, but is there a legal requirement to get one?

 

[A&S Conversions]

Just out of curiosity, is a determination letter mandatory for a product like this? I understand why you would want one and refuse to manufacture or sell without one and am not suggesting you do otherwise, but is there a legal requirement to get one?

This is a very complex question that I might or might not have the answer to. When I formed the idea for this system, I asked several RKI whether what I wanted to do would be considered a firearm. I gave them the reasons I thought it was not according to the law as I understand it. Everyone one seemed to agree with my reasoning, but no one said "Oh absolutely that is not a firearm." So we produced a proof of concept and submitted it. The FATD determination stated that the item was an accessory and was not controlled by the Gun Control Act of '68 or the amended National Firearms Act of '34.

I don't believe that there is a statute that would require a SOT to submit. But if there is any change including materials that might effect whether or not an item is or is not controlled by the GCA '68 or NFA. There are procedures for transferring a firearm or a machinegun for a 07 manufacturer must follow. If there was no determination, then the 07 manufacturer could be in violation registration and transfer of a firearm. As a non SOT manufacturing, not keeping track of and transferring firearms could be a big legal issue.

If the item(s) in question are not firearms, then there isn't a problem. But without the determination, how do you know for sure? With the amount of money involved and the possible liabilities that could be involved, it is nothing I would want to guess at.

Scott
Manager A&S Conversions L.L.C.

 

[Fishman]

Considering that you have a determination on the prototype, I personally would just make the production version. Get a determination letter after you start running production or not at all. This decision is a risk, but it comes with a reward of coming to market sooner.

You aren't breaking any laws. They were ok with your prototype. Theres zero reason for them to say no. I wouldn't give them the chance to change their minds.

I wouldnt blame anyone for waiting 120 extra days just to be sure.

 

[arch stanton]

Considering that you have a determination on the prototype, I personally would just make the production version. Get a determination letter after you start running production or not at all. This decision is a risk, but it comes with a reward of coming to market sooner.

You aren't breaking any laws. They were ok with your prototype. Theres zero reason for them to say no. I wouldn't give them the chance to change their minds.

I wouldnt blame anyone for waiting 120 extra days just to be sure.

They will change their minds whenever they want. It has been done after determination letters have stated good to go before

 

[Fishman]

They will change their minds whenever they want. It has been done after determination letters have stated good to go before

That kinda proves that the determination letter is worthless