A Florida FFL should not treat federal FRT developments as a safe harbor for inventory, installation, offers, sales, or shipments occurring from Florida. The core issue is not only the customer’s residence; it is the conduct occurring in Florida and the breadth of Florida Statutes section 790.222.
Do not inventory, install, offer, sell, or ship a forced-reset trigger from Florida solely on the premise that the product is not a federal machinegun. Obtain a product-specific Florida legal opinion and consider an FDLE declaratory statement before committing to the activity.
Why Florida is different
Section 790.222 prohibits importing, transferring, distributing, selling, keeping for sale, offering for sale, possessing, or giving another person a statutorily defined “bump-fire stock.” Its definition reaches a conversion kit, tool, accessory, or device used to alter a firearm’s rate of fire to mimic automatic fire or to increase the rate beyond what a person could achieve unassisted. The supplied statute identifies a third-degree felony and contains no express FFL, commercial inventory, out-of-state customer, or immediate-export exception.
Florida HB 6021 would have repealed section 790.222, but the official bill history shows that it died in the Criminal Justice Subcommittee on March 13, 2026. The existing statute therefore remains an active part of the state-law analysis.
What Roberts does—and does not—establish
The Roberts v. Swearingen record may support an argument that a modification preserving one round per trigger operation falls outside the statute. But neither attached order is a binding appellate merits construction of a modern FRT. The tested items included a Slide Fire stock, modified hex bolt, and screwdriver. The disposition order dismissed for lack of standing; it did not establish a commercial safe harbor for modern forced-reset trigger models.
Federal and state questions must be run separately
Following Cargill, the Northern District of Texas concluded in 2024 that the FRTs at issue could not be classified as machineguns, and DOJ announced a settlement of related federal litigation in May 2025. That federal position materially changes the federal classification analysis for covered products. It does not preempt a separate state device statute. DOJ’s own settlement announcement recognizes that state law remains a distinct issue.
Loose-part treatment depends on the exact design and any federal classification.
High exposure if possession, offer, sale, or distribution occurs in Florida.
Interstate firearm-transfer rules and possible manufacturer licensing apply.
Higher exposure because Florida inventory, installation, and sale conduct are added.
That operation’s license, configuration, and transfer rules govern.
Potentially viable only if inventory, installation, offer, fulfillment, and disposition truly occur outside Florida.
Operational controls
- Obtain a product-specific conclusion from qualified Florida firearms counsel.
- Consider requesting an FDLE declaratory statement addressing the exact manufacturer and model.
- Do not assume an “FFL-to-FFL only” policy cures Florida possession, offer-for-sale, or distribution issues.
- If using an out-of-state operation, separate inventory, installation, fulfillment, and disposition in substance—not merely on paper.
- Whitelist destinations after reviewing the product, resulting firearm configuration, dealer restrictions, local law, and destination-state law.
- Analyze whether regular installation and resale creates Type 07 manufacturing, marking, record, AFMER, or excise-tax obligations.
This page does not decide whether any specific FRT is covered by section 790.222. That requires the exact product, its mechanical operation, current state authority, and a legally accountable product-specific review.