WHAT ARE THE PRINCIPAL CHANGES?
This guidance was last updated in 2022. Most of the updates now made reflect recent changes in legislation. Not all are covered, and remember that some of what was in the previous 2016 version relating to suitability is now within the Statutory Guidance, which was last updated in August 2025.
I will highlight those areas most likely to be of interest to the trade. Paragraph numbers in brackets [X.XX] are those in the July 2026 version.
SOUND MODERATORS
We wrote about this topic recently, highlighting that these are no longer subject to certification. The Home Office have now revised this Guidance to reflect that. Paragraph 12.77 makes clear that sound moderators and flash hiders (a ‘relevant accessory’) are no longer ‘firearms’ and not subject to licensing control. The only remaining control is that it is an offence to possess such an item which is an accessory to a firearm “to which Section 1 applies” without holding a firearm or shotgun certificate. That would include a Section 5 firearm. In any other circumstances it is not an offence to hold the accessory if the person has another authority to possess firearms. These are listed in 12.78 and include RFDs; those with a police permit; auctioneers, carriers etc; members of HO approved clubs; TV & film, visitors permits and a few others.
BLANK FIRING IMITATIONS
These must conform with the Violent Crime Reduction Act Regulations 2011 on importation. Conversion of firearms must be done in accordance with those Regulations [2.41].
The recent ‘decision’ by the NCA to declare certain models of blank firer is covered [2.41]. The phrase used in the Guidance is such items ‘have been found to be readily convertible’. This is debatable. It is based on the opinion of a prosecution expert which is not universally shared. There has not, to my knowledge, as yet been a prosecution regarding this claim which has confirmed that view following a trial.
AIR WEAPONS AND PAINTBALL GUNS
This topic has been covered in more detail [2.45 to 2.52]. The Guidance summarises the law well. Under 6 (pistol) or 12 (rifle) foot pounds, these are legal, whether powered by air or carbon dioxide. Importantly, it makes clear that items designed to discharge paint pellets used in adventure games “are unlikely to cause serious injury, nor were they designed as weapons” [2.49]. However, it adds: “Designs of ‘paintball’ guns which can fire different types of projectile or are being marketed for self-defence may, however, be ‘lethal barrelled weapons’ and therefore subject to the requirements of the Firearms Act 1968. The type of ammunition held in conjunction with such guns may have a bearing on the matter”. This is a reference to the Umarex HDR50 and similar which are sometimes advertised as being for ‘home defence’ as well as paint balling. Those who possess such items might find themselves prosecuted if they also have hard ammunition for it. It might then be classified as a ‘weapon’, i.e. a firearm producing more than 1 Joule.
ITEMS NOT CONSIDERED FIREARMS
This has been expanded to include cable cutters; armoured vehicle smoke dischargers and rifled chokes for shotguns [2.57]. All items that are not considered to be weapons, although they might be quite dangerous.
3D PRINTING
As all readers will be aware, it has long been a serious offence to manufacture, sell or possess firearms without the relevant certificate or authority. Sections 52 and 53 of the Border Security, Asylum and Immigration Act 2025 has now created an offence to ‘possess a relevant article in circumstances which give rise to a
reasonable suspicion that the relevant article will be used in connection with any serious offence’. A ‘relevant article’ includes a ‘3D printer firearms template’. This is further defined as ‘any document that may be used in conjunction with a 3D printer to produce any part of a firearm (as defined by Section 57 of the Firearms Act 1968…’ Section 57 of the 1968 Act only defines what we all know as the ‘relevant’ component parts, the barrel, chamber, cylinder, etc. The items which would be separately recorded on a certificate.
Paragraphs 3.7 and 3.8 of the Guidance cover this topic, but simply repeat the wording of the Act. This is onerous legislation which imposes a burden on the suspect to demonstrate that they did not possess the document in connection with any serious offence. However the person would only have to provide ‘enough evidence to raise an issue in respect of it’. No legitimate RFD need worry about this. The mere fact that you are an RFD should be sufficient to explain why you would have such a document. Ordinary individuals would need to demonstrate that their reasons for possessing such a document was for interest and not for the purposes of serious crime.
Overall dealers need not be concerned that the updated Guidance is going to make it more difficult or onerous for you to conduct your business.