[Federal Register Volume 91, Number 14 (Thursday, January 22, 2026)]
[Rules and Regulations]
[Pages 2698-2708]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-01141]


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DEPARTMENT OF JUSTICE

Bureau of Alcohol, Tobacco, Firearms, and Explosives

27 CFR Part 478

[Docket No. ATF-2026-0034; ATF No. 2025R-54T]
RIN 1140-AB03


Revising Definition of ``Unlawful User of or Addicted to 
Controlled Substance''

AGENCY: Bureau of Alcohol, Tobacco, Firearms, and Explosives, 
Department of Justice.

ACTION: Interim final rule; request for comments.

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SUMMARY: The Bureau of Alcohol, Tobacco, Firearms, and Explosives 
(``ATF'') is amending Department of Justice (``Department'') 
regulations to update the definition of ``unlawful user of or addicted 
to any controlled substance,'' a category of persons who may not 
possess firearms under federal law. This definition was established in 
1996 to facilitate operation of the National Instant Criminal 
Background Check System. Since then, court decisions and ATF internal 
guidance have evolved to include recurring use as a factor. As a 
result, ATF is aligning the definition with the best statutory 
understanding, as informed by judicial decisions.

DATES: This interim final rule (``IFR'') is effective on January 22, 
2026. Comments must be submitted in writing, and must be submitted on 
or before (or, if mailed, must be postmarked on or before) June 30, 
2026. Commenters should be aware that the federal e-rulemaking portal 
comment system will not accept comments after midnight Eastern Time on 
the last day of the comment period. ATF will publish a final rule in 
the Federal Register adopting the IFR as final with any changes in 
response to public comments or adopting the IFR as final without 
change.

ADDRESSES: You may submit comments, identified by RIN 1140-AB03, by 
either of the following methods--
     Federal e-rulemaking portal: https://www.regulations.gov. 
Follow the instructions for submitting comments.
     Mail: ATF Rulemaking Comments; Mail Stop 6N-518, Office of 
Regulatory Affairs; Enforcement Programs and Services; Bureau of 
Alcohol, Tobacco, Firearms, and Explosives; 99 New York Ave. NE, 
Washington, DC 20226; ATTN: RIN 1140-AB03.
    Instructions: All submissions must include the agency name and 
number (RIN 1140-AB03) for this IFR. ATF may post all properly 
completed comments it receives from either of the methods described 
above, without change, to the federal e-rulemaking portal, https://www.regulations.gov. This includes any personally identifying 
information (``PII'') or business proprietary information (``PROPIN'') 
submitted in the body of the comment or as part of a related attachment 
they want posted. Commenters who submit through the federal e-
rulemaking portal and do not want any of their PII posted on the 
internet should omit it from the body of their comment or in any 
uploaded attachments that they want posted. If online commenters wish 
to submit PII with their comment, they should place it in a separate 
attachment and mark it at the top with the marking ``CUI//

[[Page 2699]]

PRVCY.'' Commenters who submit through mail should likewise omit their 
PII or PROPIN from the body of the comment and provide any such 
information on the cover sheet only, marking it at the top as ``CUI//
PRVCY'' for PII, or as ``CUI//PROPIN'' for PROPIN. For detailed 
instructions on submitting comments and additional information on the 
rulemaking process, see the ``Public Participation'' heading of the 
SUPPLEMENTARY INFORMATION section of this document. You may find a 
summary of this rule at https://www.regulations.gov. Commenters must 
submit comments by using one of the methods described above, not by 
emailing the address set forth in the following paragraph.

FOR FURTHER INFORMATION CONTACT: Office of Regulatory Affairs, by email 
at [email protected], by mail at Office of Regulatory Affairs; Enforcement 
Programs and Services; Bureau of Alcohol, Tobacco, Firearms, and 
Explosives; 99 New York Ave. NE, Washington, DC 20226, or by telephone 
at 202-648-7070 (this is not a toll-free number).

SUPPLEMENTARY INFORMATION:

I. Background

    The Attorney General is responsible for enforcing the Gun Control 
Act of 1968 (``GCA''), as amended. This responsibility includes the 
authority to promulgate regulations necessary to enforce the provisions 
of the GCA.\1\ See 18 U.S.C. 926(a). Congress and the Attorney General 
delegated the responsibility for administering and enforcing the GCA to 
the Director of ATF (``Director''), subject to the direction of the 
Attorney General and the Deputy Attorney General. See 28 U.S.C. 
599A(b)(1), (c)(1); 28 CFR 0.130(a)(1)-(2); Treas. Order No. 221(2)(a), 
(d), 37 FR 11696-97 (June 10, 1972).\2\ Accordingly, the Department and 
ATF have promulgated regulations to implement the GCA in 27 CFR part 
478.
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    \1\ Some GCA provisions still refer to the ``Secretary of the 
Treasury.'' However, the Homeland Security Act of 2002, Public Law 
107-296, 116 Stat. 2135, transferred the functions of ATF from the 
Department of the Treasury to the Department of Justice, under the 
general authority of the Attorney General. 26 U.S.C. 7801(a)(2); 28 
U.S.C. 599A(c)(1). Thus, for ease of reference, this IFR refers to 
the Attorney General where relevant.
    \2\ In Attorney General Order Number 6353-2025, the Attorney 
General delegated authority to the Director to issue regulations 
pertaining to matters within ATF's jurisdiction, including under the 
GCA, National Firearms Act, and Title XI of the Organized Crime 
Control Act. ATF's jurisdiction also includes the Arms Export 
Control Act and the Contraband Cigarette Trafficking Act.
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     The GCA, in 18 U.S.C. 922(g)(3), states that it is unlawful for 
any person who is an unlawful user of or addicted to any controlled 
substance (as defined by section 102 of the Controlled Substances Act 
at 21 U.S.C. 802) to ship, transport, possess, or receive any firearm 
that has moved through interstate or foreign commerce. In other words, 
persons who are unlawful users of or addicted to a controlled substance 
constitute one category of what are commonly referred to as 
``prohibited'' persons in the context of firearms. The plain language 
of the text indicates that the person must be a current unlawful user 
of a controlled substance, contemporaneous to possessing the firearm.
    After the GCA was passed in 1968, federal courts addressed the 
meaning of ``unlawful user'' and recognized the distinction between 
``use'' and ``addiction.'' One court observed that ``the statute 
prohibits a person who is either an unlawful user of or addicted to a 
controlled substance from purchasing firearms.'' \3\ Another court 
noted that if the defendant's use of heroin had been infrequent or in 
the distant past, the term ``unlawful user'' would be subject to a 
vagueness challenge.\4\
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    \3\ United States v. Corona, 849 F.2d 562, 563 n.2 (11th Cir. 
1988) (emphases in original).
    \4\ United States v. Ocegueda, 564 F.2d 1363, 1366 (9th Cir. 
1977).
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    ATF proposed a regulatory definition of unlawful user, together 
with other regulatory definitions on the prohibited person categories, 
in 1996 to facilitate operating the National Instant Criminal 
Background Check System (``NICS''), as required by the Brady Handgun 
Violence Prevention Act, Public Law 103-159 (1993).\5\ The definition 
of ``unlawful user'' utilized definitions from both the Americans with 
Disabilities Act, Public Law 101-336 (1990); and the Controlled 
Substances Act, Public Law 91-513 (1970),\6\ and the proposed rule 
included some of the current regulations' factual examples that give 
rise to an inference of being an unlawful user.\7\
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    \5\ See Definitions for the Categories of Persons Prohibited 
From Receiving Firearms (95R-051P), 61 FR 47095, 47096, 47098 (Sep. 
6, 1996) (proposed rule).
    \6\ Id. at 47096 (explaining that the proposed definition of 
``unlawful user of or addicted to any controlled substance'' is 
consistent with similar terms used in 18 U.S.C. 802, 42 U.S.C. 
12101-12213, and 21 U.S.C. 802).
    \7\ Id. at 47099 (``An inference of current use may be drawn 
from evidence of a recent use or possession of a controlled 
substance or a pattern of use or possession that reasonably covers 
the present time, e.g., a conviction for use or possession of a 
controlled substance within the past year, or multiple arrests for 
such offenses within the past five years if the most recent arrest 
occurred within the past year.'').
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    Thereafter, in June 1997, ATF published implementing regulations at 
27 CFR 478.11, further defining the term ``unlawful user of or addicted 
to any controlled substance'' to provide more clarity.\8\ The 
regulatory definition first clarified that the two prongs of the 
definition consist of (1) persons who use a controlled substance and 
have ``lost the power of self-control with reference to the use'' of 
the substance, and (2) persons who are ``current user[s]'' of a 
controlled substance ``in a manner other than as prescribed by a 
licensed physician.'' The definition then clarified the temporal 
component by stating that ``use'' of the controlled substance is not 
limited to a particular day or within a matter of days or weeks before 
shipping, transporting, receiving, or possessing a firearm, but rather 
that ``the unlawful use has occurred recently enough to indicate that 
the individual is actively engaged in such conduct'' and that the 
person can be an unlawful current user even if the substance is ``not 
being used at the precise time the person seeks to acquire a firearm or 
receives or possesses a firearm.'' The regulation further clarified 
that inferences of ``current use'' may arise from ``evidence of a 
recent use or possession'' of the substance or ``a pattern of use or 
possession that reasonably covers the present time'' and provided 
examples from which a person may draw an inference of current use, 
including:
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    \8\ See Definitions for the Categories of Persons Prohibited 
From Receiving Firearms (95R-051P), 62 FR 34634 (June 27, 1997) 
(``1997 final rule'').
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     a conviction for use or possession within the past year;
     multiple arrests for such offenses within the past five 
years if the most recent arrest occurred within the past year;
     a drug test finding the person used a controlled substance 
unlawfully, provided the test was within the past year; or
     for current or former Armed Forces members, a recent 
disciplinary or other administrative action based on confirmed drug use 
(including a court-martial conviction, non-judicial punishment, or 
administrative discharge based on drug use or rehabilitation failure).
    The 1997 final rule added factual examples supporting an inference 
of current use, as recommended by certain Department components other 
than ATF, as well as the Department of Defense. These additions 
included inferences based on a positive drug test within the past year 
and military nonjudicial or administrative actions based on drug use 
\9\--both of which could result from a single unlawful use.

[[Page 2700]]

The regulatory definition thus described what ATF at the time 
understood the term ``unlawful user'' to mean and, as relevant here, it 
included an understanding that a single incident of unlawful use could 
make a person an ``unlawful user.''
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    \9\ 1997 final rule at 34636.
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    Thereafter, without exception, federal courts in the early 2000s 
agreed that, to put defendants on notice that they are unlawful users 
pursuant to the GCA, ``one must be an unlawful user at or about the 
time he or she possessed the firearm and that to be an unlawful user, 
one needed to have engaged in regular use over a period of time 
proximate to or contemporaneous with the possession of the firearm.'' 
\10\ Under this analysis, federal courts consistently upheld 
convictions in which there was evidence that an individual used 
controlled substances on a regular basis, establishing a pattern of 
use.\11\ For example, courts have upheld convictions in which the 
defendant admitted to smoking marijuana twice a day for many years; 
\12\ the suspect admitted he had been using the drug in question for 
two years; \13\ and a user-quantity amount of amphetamine was found on 
a table in the defendant's residence, where he lived alone, and 
testimony established the defendant frequently used drugs with his 
customers.\14\
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    \10\ United States v. Augustin, 376 F.3d 135, 139 (3d Cir. 
2004).
    \11\ See United States v. Burchard, 580 F.3d 341, 352-53 (6th 
Cir. 2009) (testimony that defendant smoked crack on numerous 
occasions for one year prior to arrest for violation of section 
922(g)(3)); United States v. Mack, 343 F.3d 929, 932-33 (8th Cir. 
2003) (evidence of unlawful use sufficient where defendant possessed 
user-quantity of marijuana at the time of his arrest and arresting 
officers smelled marijuana, and where one month earlier defendant 
had confronted witness about theft of his marijuana and fired a gun 
into the air).
    \12\ United States v. Jackson, 280 F.3d 403, 406 (4th Cir. 
2002).
    \13\ United States v. Patterson, 431 F.3d 832, 835 (5th Cir. 
2005).
    \14\ United States v. Oleson, 310 F.3d 1085, 1090 (8th Cir. 
2002).
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    Courts also issued decisions in the early 2000s regarding the other 
end of the unlawful-user boundary. They held that an individual may not 
be convicted of violating 18 U.S.C. 922(g)(3) when the government is 
able to prove only a single use of a controlled substance instead of 
regular use.\15\ For example, the Ninth Circuit held that, ``to sustain 
a conviction'' under section 922(g)(3), the government ``must prove . . 
. that the defendant took drugs with regularity, over an extended 
period of time, and contemporaneously with his purchase or possession 
of a firearm.'' \16\ The Eighth Circuit noted that ``courts generally 
agree the law runs the risk of being unconstitutionally vague without a 
judicially-created temporal nexus between possessing the gun and 
regular drug use.'' \17\ The federal circuits that have weighed in on 
this issue have held that the government must prove some regularity of 
drug use in addition to contemporaneousness to meet the statute's 
requirements.\18\
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    \15\ See United States v. Williams, 216 F. Supp. 2d 568, 576 
(E.D. Va. 2002) (motion for judgment of acquittal must be granted 
where there is no evidence suggesting a pattern of use, continuous 
use, or prolonged use of a controlled substance on the part of the 
defendant); United States v. Freitas, 59 M.J. 755, 757-58 (N-M. Ct. 
Crim. App. 2004) (where the government proves only a single use of 
marijuana by service member, the record lacks an adequate factual 
basis to substantiate that the appellant was an ``unlawful user'' 
under section 923(d)(3)); United States v. Herrera, 289 F.3d 311, 
323-24 (5th Cir. 2002), rev'd en banc on other grounds, 313 F.3d 882 
(5th Cir. 2002) (irregular use of cocaine and past use of marijuana 
was insufficient evidence to establish that appellant was a 
prohibited person under section 923(g)(3)).
    \16\ United States v. Purdy, 264 F.3d 809, 812-13 (9th Cir. 
2001).
    \17\ United States v. Turnbull, 349 F.3d 558, 561 (8th Cir. 
2003), cert. granted, judgment vacated on other grounds, 543 U.S. 
1099 (2005).
    \18\ See e.g. United States v. Marceau, 554 F.3d 24, 30-31 (1st 
Cir. 2009); United States v. Yepez, 456 F. App'x 52, 54-55 (2d Cir. 
2012); Augustin, 376 F.3d at 138-39; Jackson, 280 F.3d at 406; 
United States v. McCowan, 469 F.3d 386, 392 (5th Cir. 2006); 
Burchard, 580 F.3d at 350; United States v. Bennett, 329 F.3d 769, 
778 (10th Cir. 2003) (noting ``a regular and ongoing use''); United 
States v. Edmonds, 348 F.3d 950, 951 (11th Cir. 2003).
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    Since ATF published the 1997 final rule, the Federal Bureau of 
Investigation (``FBI''), in operating NICS, has relied on the inference 
examples in the regulatory definition of unlawful user. The NICS 
Section concluded, with ATF's concurrence, that the FBI could draw an 
inference of a person currently using or possessing a controlled 
substance from evidence of a recent incident, and that ATF's regulation 
indicated that the relevant time period was ``within the past 12 
months.'' Based upon those historical factors, NICS examiners have, for 
example, found prohibited use when, within the past year, the person 
has had a drug conviction for using or possessing; admitted to using or 
possessing; had any positive drug test, or was convicted of a 
misdemeanor crime involving drugs.
    The NICS Section also advised federal, state, local, and tribal 
NICS users that they could temporarily enter identifying information 
about individuals fitting such conditions into the NICS Indices.\19\ 
These Indices contain information provided by federal, state, local, 
and tribal agencies on actions that could cause a person to be 
prohibited from receiving firearms under federal or state law.\20\ As 
of December 31, 2025, there were 54,136 entries in the NICS Indices 
designated as ``unlawful user/addicted to controlled substance,'' out 
of a total of 34,036,267 active entries in the NICS Index alone (one of 
the three systems that make up the Indices).\21\
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    \19\ The NICS background-check process encompasses information 
from the NICS Index, the National Crime Information Center, and the 
Interstate Identification Index. See 28 CFR 25.2, 25.4. The FBI, and 
therefore this rule, refers to these databases as the ``NICS 
Indices.'' The ``NICS Indices'' was originally termed the ``NICS 
Index.'' The NICS Index is now ``the database, to be managed by the 
FBI, containing information provided by federal and state agencies 
about persons prohibited under federal law from receiving or 
possessing a firearm. The NICS Index is separate and apart from the 
[National Crime Information Center (NCIC)] and the Interstate 
Identification Index (III).'' 28 CFR 25.2.
    \20\ FBI Criminal Justice Information Services Division 
(``CJIS''), Quick Reference Information, (Dec. 31, 2024), https://www.fbi.gov/file-repository/cjis/download-active-entries-in-the-nics-indices-as-of-december-31-2023.pdf.
    \21\ FBI CJIS, Active Entries in the NICS Indices (last updated 
Dec. 31, 2025), https://www.fbi.gov/file-repository/cjis/active_records_in_the_nics-indices.pdf/view. These numbers represent 
a snapshot in time because records are constantly moving in and out 
of the system as federal and state agencies add or remove records 
based on prohibiting criteria in 18 U.S.C. 922. The FBI NICS Section 
updates the metrics on a monthly basis. This section runs a report 
showing the total entries in the NICS Indices at that time, and 
which prohibited category was involved, for tracking purposes.
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    Under 18 U.S.C. 922(t)(1), federal firearms licensees must 
generally contact NICS prior to transferring a firearm to a purchaser. 
Based on ATF's current regulatory definition and NICS's implementing 
criteria, NICS may deny transfers to certain firearm purchasers based 
on NICS Indices entries indicating the persons admitted they used or 
possessed unlawful drugs a single time within the past year. In such 
cases, NICS notifies the licensee that the transfer is prohibited or 
``denied.'' See 28 CFR 25.6. However, if the licensee does not receive 
such notification from NICS within three business days, federal law 
says the licensee may generally transfer the firearm to the purchaser 
the next day. In a situation in which NICS determines that the 
purchaser is prohibited after the firearm has been transferred 
(``delayed denial''), the FBI refers the case to ATF's Denial 
Enforcement and NICS Intelligence Branch (``DENI'') to potentially 
investigate and retrieve the firearm from the prohibited purchaser.
    Since the 1997 final rule, ATF's internal practices and guidance 
have evolved within the boundaries established by court decisions like 
those described above. For example, each of ATF's field divisions, in 
conjunction with the local United States Attorney's Office (``USAO''), 
establishes referral

[[Page 2701]]

guidelines to reflect the USAO's current policies. Accordingly, the ATF 
Special Agent in Charge of each field division reviews the referral 
guidelines annually with the relevant USAO. In those referral 
guidelines, ATF states that most kinds of single ``inference of use'' 
denials (i.e., admitted use, admitted possession, positive drug test, 
or a single drug arrest in the past year) should not be referred to 
field offices for prosecution or to retrieve a purchased firearm. This 
guideline also generally applies to firearms forfeiture because field 
divisions do not retrieve or seize firearms based on evidence of a 
single unlawful use. Since approximately April 2018, DENI policy has 
been to not refer delayed denials or standard denials based on the 
kinds of inferences arising from a single incident of drug use listed 
above. However, DENI has referred an 18 U.S.C. 922(g)(3) denial to a 
field office if the purchaser has a misdemeanor drug conviction within 
the past year or multiple drug arrests in the past five years with at 
least one of those arrests being in the past year.
    As a result, ATF field divisions receiving NICS delayed-denial 
referrals based on single-use situations have often determined that, 
contrary to the regulatory inferences in 27 CFR 478.11, a single 
incident is insufficient evidence on which to pursue a violation under 
18 U.S.C. 922(g)(3). In fiscal year (``FY'') 2025, NICS denied 
approximately 9,163 transfers under an 18 U.S.C. 922(g)(3) prohibitor 
due to records of drug-related incidents. Of this number, ATF did not 
refer 8,893 cases for further investigation. Of the ones that ATF did 
not refer further, 8,697 cases were standard denials (no firearm was 
transferred), and the remaining 196 cases were delayed denials (a 
firearm was transferred before the denial notification arrived from 
NICS). Of the cases that ATF did refer for further investigation, 120 
were standard denials (i.e., although the person did not receive the 
firearm, the person was referred for other reasons, such as repeated 
efforts to purchase a firearm while prohibited), and 130 were delayed 
denials. Table 1 shows these numbers.

                Table 1--FY 2025 NICS Denials Under 18 U.S.C. 922(g)(3) Unlawful User Prohibition
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Total FY 2025 NICS denials under 18 U.S.C.                                                Standard     Delayed
                 922(g)(3)                           Disposition              Totals      denials      denials
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9,163.....................................  Not referred by ATF for              8,893        8,697          196
                                             further action.
                                            Referred by ATF for further            250          120          130
                                             action.
                                            Overturned, cancelled, etc...           29          n/a          n/a
                                                                          --------------------------------------
                                               Total by denial type......  ...........        8,817          326
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    Therefore, of the 9,163 cases, 8,947 (8,697 + 120 + 130 in Table 1) 
resulted in a person not receiving a firearm either through standard 
denials (8,817) or delayed denials in which ATF retrieved the firearm 
(120). Of the 326 cases NICS referred to ATF as delayed denials under 
an 18 U.S.C. 922(g)(3) prohibition, ATF pursued only 130 for further 
investigation, firearms forfeiture, or prosecution (which included 80 
based on a single misdemeanor conviction). ATF did not pursue the 
remaining 196 delayed denial cases because they involved an inference 
based on a single use that did not involve a conviction (such as an 
admitted use, admitted possession, or positive drug test in the past 
year). Table 2 shows the inference break-down numbers for each type of 
denial.

                           Table 2--FY 2025 Single-Incident Inference Denials by Type
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                                                                             Delayed denials    Delayed denials
            Inference (1x during last year)               Standard denials     not referred         referred
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Admitted drug use......................................              1,032                 86                  0
Admitted drug possession...............................                853                 54                  0
Positive drug test.....................................                881                 60                  0
Misdemeanor drug use conviction........................              2,018                  9                 80
                                                        --------------------------------------------------------
    Totals by denial type..............................              4,784                209                 80
Adjusted totals by denial type *.......................              4,284                196                 80
                                                        --------------------------------------------------------
    Total inference denials............................                  4,560                 .................
----------------------------------------------------------------------------------------------------------------
* Totals adjusted to account for duplicates (persons with more than one category for the same incident).

    As illustrated by Tables 1 and 2, and as described above regarding 
the number of overall NICS entries, in FY25, out of the millions of 
NICS checks that occurred, approximately 9,163 checks resulted in a 
``denied'' response from NICS due to unlawful-user status. From among 
that number, approximately 4,364 persons were denied a firearm in FY25 
based on the single-use inferences in ATF's regulations (approximately 
4,560 single-use ``denied'' responses-196 who got firearms (ATF did not 
retrieve them because the denial was based on a single-use inference) = 
approximately 4,364 denied firearms).
    Concurrently, court decisions have continued to emphasize the 
element of habitual or regular use. Between 2019 and 2025, for example, 
the Fourth, Sixth, Seventh, Eighth, and Tenth Circuits \22\ 
consistently found that the government must prove some variation of the 
concept ``that the defendant took drugs with regularity, over an 
extended

[[Page 2702]]

period of time, and contemporaneously with his purchase or possession 
of a firearm'' \23\ and that there must be a ``temporal nexus'' to 
``regular and ongoing'' drug use.\24\
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    \22\ See, e.g., United States v. Davey, 151 F.4th 1249, 1255 
(10th Cir. 2025) (``temporal nexus'' between regular drug use and 
firearm possession); United States v. Seiwert, 152 F.4th 854, 861 
(7th Cir. 2025) (``active and persistent drug users''); United 
States v. Hasson, 26 F.4th 610, 615 (4th Cir. 2022) (section 
922(g)(3) prohibits the ``possession of firearms by an individual 
whose drug use is consistent, prolonged, and close in time to his 
firearm possession''); United States v. Carnes, 22 F.4th 743, 748 
(8th Cir. 2022) (``[W]e interpreted Sec.  922's `unlawful user' 
element to require a temporal nexus between the proscribed act (for 
Sec.  922(g)(3), possession of a firearm) and regular drug use.'').
    \23\ United States v. Bowens, 938 F.3d 790, 793 (6th Cir. 2019) 
(internal citations omitted).
    \24\ United States v. Morales-Lopez, 92 F.4th 936, 945-46 (10th 
Cir. 2024).
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II. Interim Final Rule (IFR)

A. Discussion

    Based on the foregoing, a disconnect has arisen between NICS 
firearm purchase determinations, ATF enforcement, and court decisions 
on what the definition of an unlawful user means. Relying on the 
inferences from ATF's current regulation, NICS denies transfers for 
those individuals who have, for example, a single admission of drug use 
in the past year, or a single failed drug test for an unlawfully used 
controlled substance within the previous year. This means that if a 
person has been documented as using a controlled substance illicitly 
even one time in the past 12 months, the person will be deemed 
temporarily prohibited under 18 U.S.C. 922(g)(3) from purchasing a 
firearm for a year from the underlying event. As Tables 1 and 2 above 
show, of the 8,817 standard NICS denials in which a person did not 
receive a firearm due to an 18 U.S.C. 922(g)(3) prohibition, 4,284 were 
predicated on an inference based on a single use. In addition, of the 
326 delayed denials, ATF referred 80 of them based on a single 
misdemeanor conviction involving drugs, for a total of 4,634 persons 
who did not receive a firearm. As indicated by ATF's enforcement 
practice and by the court decisions discussed above, such denials do 
not reflect the best understanding of section 922(g)(3). In addition, 
such denials create unnecessary constitutional questions. See Ocegueda, 
564 F.2d at 1366 (noting that section 922(g)(3) would create vagueness 
issues if construed to deny a firearm to those whose drug use was 
``infrequent and in the distant past''). The prevailing opinion of many 
federal courts is that such denials are no longer supported under 
section 922(g)(3) and create unnecessary constitutional questions.
    Accordingly, it would be inappropriate to retain inference examples 
in the regulatory definition which suggest that an admission or other 
evidence of a single use-related event--including a single conviction 
or a single failed drug test--occurring in the past 12 months is 
sufficient evidence upon which to base an administrative forfeiture, to 
prosecute an individual for unlawfully possessing a firearm under 
section 922(g)(3), or to deny a firearm transaction. This type of 
determination must be made based on evidence that indicates an 
individual regularly uses a controlled substance unlawfully. The 
current inference examples result in denied transactions that are not 
consistent with the prevailing interpretation of 922(g)(3).
    Based on the current case law, it is appropriate to remove the 
inference examples of ``current use'' to instead require evidence of a 
pattern of unlawful use. The current inferences establish bright line 
rules for an inquiry that should be determined on a case-by-case basis. 
Also, the current inferences create confusion for those, like law 
enforcement organizations, courts, NICS users, and persons possessing 
firearms, who rely upon the current regulation's provisions. As a 
result, ATF is revising its definition of ``unlawful user of or 
addicted to any controlled substance.'' Removing the inference examples 
will help reduce confusion for NICS determinations, will prevent 
erroneous NICS denials for people possessing firearms, and will better 
align ATF's regulations with the best interpretation of section 
922(g)(3). Future section 922(g)(3) NICS determinations that deny 
firearm transactions, and future ATF enforcement decisions, will 
therefore require evidence of regular and recent use.
    In addition, ATF is also removing the other examples included in 
the current regulation. Currently, the regulation covers ``a conviction 
for use or possession of a controlled substance within the past year''; 
``multiple arrests for such offenses within the past 5 years if the 
most recent arrest occurred within the past year''; and failing a drug 
test establishing a person used a controlled substance, ``, provided 
that the test was administered within the past year.'' The regulation 
also includes a separate sentence with examples for members of the 
Armed Forces that contains both single-use inference examples and 
others. ATF is removing both sets of examples, even those that do not 
involve single-use inferences. During the course of assessing the 
single-use inference examples in light of court decisions and 
operational practices, ATF found that the other examples were often 
being intertwined with the single-use ones or had aspects that relate 
to questions about single-use decisions. For instance, the regulatory 
example for multiple arrests within the past five years if the most 
recent arrest occurred within the past year sometimes includes one 
event from five years ago and another from the current year. Such a 
fact pattern fits the regulatory example, but it does not demonstrate 
regular use because of the time gap between events, and it thus results 
in a problem very similar to the ones arising under the single-use 
inference examples.
    As a result, because of the impact the examples overall are having 
on persons' ability to purchase firearms, ATF has determined that it is 
necessary to remove the examples in full, while clarifying that the 
prohibition in 18 U.S.C. 922(g)(3) requires that the records show a 
person is regularly using or possessing controlled substances, as 
described in the discussion above. This is an interim measure to 
address the harm to constitutional rights caused by erroneously denying 
a person a firearm while ATF further assesses whether new examples 
might be useful or feasible, given the variety of case-by-case fact 
patterns. ATF may reassess the definition of unlawful user in a 
separate notice of proposed rulemaking after the pending case United 
States v. Hemani concludes at the Supreme Court and considering any 
public comments in response to this IFR, or it may make amendments in a 
final rule based on this interim one. In the meantime, any erroneous 
denials based on the examples in the current definition will cease.

B. Specific Changes

    To make the definition of ``[u]nlawful user of or addicted to any 
controlled substance'' easier to read, and to distinguish more clearly 
between the two prongs of the definition, ATF is breaking the 
definition into multiple paragraphs and has made minor plain-writing 
edits throughout. The first paragraph of the revised regulatory text in 
this rule defines when a person is addicted to a controlled substance. 
ATF is slightly revising the wording of this definition for better 
medical accuracy, so it now reads, ``A person who uses a controlled 
substance and demonstrates a pattern of compulsive use of the 
controlled substance, characterized by impaired control over use, is 
addicted to a controlled substance.'' The second paragraph defines an 
unlawful user of a controlled substance, and the remaining portions of 
the current definition fall within subparagraphs under paragraph (2).
    ATF is revising the definition of an unlawful user to specifically 
provide that an ``unlawful user'' is someone who uses a controlled 
substance regularly over an extended period of time.\25\ The

[[Page 2703]]

new definition therefore adds ``over an extended period of time 
continuing into the present.'' It also clarifies that using a 
controlled substance without a lawful prescription also qualifies as 
unlawful use. As a result, the new definition reads: ``A person who 
regularly uses a controlled substance over an extended period of time 
continuing into the present, without a lawful prescription or in a 
manner substantially different from that prescribed by a licensed 
physician, is an unlawful user of a controlled substance.''
---------------------------------------------------------------------------

    \25\ Regular use in this rule is a legal construct, distinct 
from a clinical diagnosis, and does not itself imply the presence of 
a substance use disorder. ATF notes that substance use alone also 
does not equate to addiction or substance use disorder. This is, in 
part, one of the reasons that the courts, and now ATF, are no longer 
relying on single-use cases to establish inferences of regular use 
under this regulation. From a medical perspective, substance use 
exists along a continuum, ranging from non-problematic use to 
clinically diagnosable substance use disorder.
---------------------------------------------------------------------------

    Paragraph (2)(i) then includes the portion of the current 
definition that sets out the temporal aspect, but it removes the phrase 
``or weeks,'' adds ``unlawful'' before ``use,'' adds ``shipping, 
transporting, possessing, or receiving a firearm'' to clarify what 
``before'' refers to, adds ``requires evidence,'' adds ``with 
sufficient regularity and recency'' to replace the existing phrase 
``recently enough,'' and makes some minor plain-writing edits so that 
the first sentence (now two sentences) reads: ``Such unlawful use is 
not limited to using a controlled substance on a particular day, or 
within a matter of days before shipping, transporting, possessing, or 
receiving a firearm. Rather, unlawful use requires evidence that the 
person has unlawfully used the substance with sufficient regularity and 
recency to indicate that the individual is actively engaged in such 
conduct. A person may be an unlawful current user of a controlled 
substance even though the substance is not being used at the precise 
time the person seeks to acquire, ship, transport, receive, or possess 
the firearm.'' This rule then adds a new clarifying sentence to this 
paragraph, which reads ``A person may be an unlawful current user of a 
controlled substance even though the substance is not being used at the 
precise time the person seeks to acquire, ship, transport, receive, or 
possess the firearm.''
    Additionally, ATF is adding a new provision to clarify when a 
person is not an unlawful user, which is in paragraph (2)(ii) and 
reads: ``A person is not an unlawful user of a controlled substance if 
the person has ceased regularly unlawfully using the substance, or if 
the person's unlawful use is isolated or sporadic or does not otherwise 
demonstrate a pattern of ongoing use. A person is also not an unlawful 
user if the person, while using a lawfully prescribed controlled 
substance, deviates slightly or immaterially from the instructions of 
the prescribing physician.'' The rule removes the remaining section of 
the current definition, the examples, from the definition.

III. Statutory and Executive Order Review

A. Administrative Procedure Act

    Under the Administrative Procedure Act (``APA''), 5 U.S.C. 
553(b)(A), an agency is not required to undergo notice and public 
comment when it issues an interpretive rule. An interpretive rule 
``typically reflects an agency's construction of a statute that has 
been entrusted to the agency to administer'' and does not modify or add 
``to a legal norm based on the agency's own authority.'' Syncor Int'l 
Corp. v. Shalala, 127 F.3d 90, 94-95 (D.C. Cir. 1997) (emphasis 
omitted).
    This rule is an interpretive rule because ATF is merely amending 
the regulation to better align it with the best interpretation of the 
statute. See, e.g., Warshauer v. Solis, 577 F.3d 1330, 1338, 1340 (11th 
Cir. 2009) (an interpretive rule ``merely clarifies how the [agency] 
intends to enforce'' a statute, and a ``statement seeking to interpret 
a statutory . . . term is . . . the quintessential example of an 
interpretive rule'' (quotation omitted)). Not only have court decisions 
over the past 25 years consistently interpreted the statute to not 
include single-use inferences and to rest on regular use or a pattern 
of use, but ATF has also been interpreting the statute that way for 
most single-use denials for more than a decade and has changed its 
referral practices accordingly. This rule informs the public about 
ATF's current view of how the statutory term ``unlawful user of or 
addicted to a controlled substance'' should be construed and clarifies 
how the Department intends to enforce it in the context of firearm 
denials. See, e.g., Perez v. Mortgage Bankers Ass'n, 575 U.S. 92, 97 
(2015) (a rule issued ``to advise the public of the agency's 
construction of the statutes and rules which it administers'' is an 
interpretive rule (quotation omitted)); Mendoza v. Perez, 754 F.3d 
1002, 1021 (D.C. Cir. 2014) (``An `interpretive rule' describes the 
agency's view of the meaning of an existing statute or regulation.'' 
(quotation omitted)); id. (interpretive rules ``are those that clarify 
a statutory or regulatory term''); Orengo Caraballo v. Reich, 11 F.3d 
186, 195 (D.C. Cir. 1993) (``A statement seeking to interpret a 
statutory or regulatory term is . . . the quintessential example of an 
interpretive rule.''). This rule creates no new law, right, or duty, 
and it has no effect independent of the statute. Rather, it provides 
guidance on how the Department will enforce the statute, principally by 
removing interpretive examples from the definition that are no longer 
aligned with the best interpretation of the statute and by clarifying 
that the definition involves regular use or a pattern of use. This rule 
does not change the prohibition or authorities created by the statute.
    Although this rule is an interpretive rule, ATF is issuing this 
rule as an IFR and soliciting public comments on possible new examples 
and other changes that might help further clarify the relevant 
definition in a possible future proposed rulemaking, or in a final rule 
stemming from this IFR, for that purpose.
    An agency may also forego the delayed effective date typically 
required by the APA ``for good cause found and published with the 
rule.'' 5 U.S.C. 553(d)(3). As to whether there is good cause to forego 
the delayed effective date typically required by the APA, courts have 
asked whether the need to immediately implement a new rule outweighs 
regulated parties' need to prepare for implementation of the rule. See, 
e.g., Riverbend Farms, Inc. v. Madigan, 958 F.2d 1479, 1485 (9th Cir. 
1992); Am. Fed'n of Gov't Emps., AFL-CIO v. Block, 655 F.2d 1153, 1156 
(D.C. Cir. 1981). Here, there is no need for additional delay for 
regulated parties to prepare to implement this rule because this rule 
does not require any regulated parties to take any actions. See 5 
U.S.C. 553(d)(1), (d)(3). Instead, this rule simply ensures that 
certain regulated parties will not be denied firearms due to an 
erroneous interpretation of 18 U.S.C. 922(g)(3).

B. Executive Orders 12866 and 13563

    Executive Order 12866 (Regulatory Planning and Review) directs 
agencies to assess the costs and benefits of available regulatory 
alternatives and, if regulation is necessary, to select regulatory 
approaches that maximize net benefits.
    Executive Order 13563 (Improving Regulation and Regulatory Review) 
emphasizes the importance of agencies quantifying both costs and 
benefits, reducing costs, harmonizing rules, and promoting public 
flexibility.
    This IFR amends 27 CFR 478.11 to bring the definition of ``unlawful 
user of or addicted to any controlled substance'' into alignment with 
court decisions and

[[Page 2704]]

ATF internal guidance that a single use of a controlled substance does 
not constitute sufficient evidence to support a determination that a 
person is an unlawful user within the statutory definition.
    The Office of Management and Budget (``OMB'') has determined that, 
although this rule is not economically significant under section 
(3)(f)(1) of Executive Order 12866, this rule is a ``significant 
regulatory action'' under the Order. OMB has therefore reviewed this 
rule. ATF provides the following analysis to comply with Executive 
Orders 12866 and 13563.
    This rulemaking provides qualitative benefits by reducing a 
regulatory burden on the public, including qualitative benefits for 
current and future firearm owners, without reducing public safety. The 
provisions of this IFR better align with field enforcement, judicial 
precedent, agency guidance, administrative processes, and public 
understanding of the key definitions and patterns that affect firearms 
purchases and prohibitions.
1. Need Statement
    This IFR is designed to correct the discrepancy that currently 
exists in enforcing section 922(g)(3) between, e.g., NICS firearm 
purchase determinations and certain ATF referrals, on the one hand, and 
court decisions, on the other hand. Relying on current ATF regulations, 
NICS denies firearm purchases for those individuals who, within the 
previous year, have had a single arrest for admitted drug use or drug 
possession, or who failed a test for an unlawfully used controlled 
substance. In addition, ATF refers certain delayed denials, those based 
on a single misdemeanor conviction involving drugs, for prosecution or 
to retrieve the firearm (including cases in which the person is subject 
to forfeiture). The inference examples that NICS and ATF rely upon for 
these actions are not supported by federal courts that have interpreted 
the phrase ``unlawful user.'' This discrepancy has created confusion 
for purchasers and those tasked with enforcing the statutory 
prohibition, has caused a divergence between court decisions and 
enforcement decisions, and has caused (and continues to cause) some 
people to be erroneously denied firearms. ATF needs to address this 
situation and has decided to revise its regulatory definition of 
``unlawful user of or addicted to any controlled substance'' to align 
with court interpretations of the definition and specifically require 
that a person must use the controlled substance regularly over an 
extended period of time, continuing into the current time, before being 
deemed an ``unlawful user of or addicted to any controlled substance.''
2. Benefits
    ATF estimates the impacts of the IFR to be primarily a reduced 
burden on the public, including qualitative benefits for current and 
future firearm owners.
    As of December 31, 2025, there were 54,136 entries in the NICS 
Indices designated as ``unlawful user/addicted to controlled 
substance'' out of a total of 34,036,267 active entries in the NICS 
Index alone (one of the three systems that make up the Indices).\26\ 
NICS uses the information in the III, NCIC, and NICS Index to assess 
whether a person wishing to receive a firearm from a licensee is 
prohibited from doing so under federal statutes, including on the basis 
of being an unlawful user of a controlled substance. If so, NICS 
notifies the licensee preparing to sell the firearm that the person is 
denied from purchasing. NICS denials may occur at any point within the 
first three business days from when the transactions were initiated, in 
which case they are called standard denials. The potentially 
prohibiting record may also take longer to investigate, and thus the 
denial may arrive after the initial three-business day period, in which 
case they are called delayed denials. During a delayed denial, the 
person may have received the firearm before the licensee is notified 
that the person was denied. NICS refers delayed-denial cases to ATF to 
pursue.
---------------------------------------------------------------------------

    \26\ FBI CJIS, Active Entries in the NICS Indices (last updated 
Dec. 31, 2025), https://www.fbi.gov/file-repository/cjis/active_records_in_the_nics-indices.pdf/view.
---------------------------------------------------------------------------

    With regard to pursuing delayed-denial referrals from NICS 
involving 18 U.S.C. 922(g)(3), ATF's field division referral guidelines 
state that most single ``inference of use'' denials (i.e., admitted 
use, admitted possession, positive drug test, or single drug arrest in 
the past year) should not be referred to the field offices to prosecute 
or to retrieve purchased firearms (including any firearms a person must 
forfeit). However, DENI refers an 18 U.S.C. 922(g)(3) denial to the 
field if the purchaser has a misdemeanor drug conviction within the 
past year (another type of single-use inference) or multiple drug 
arrests in the past five years with at least one of those arrests being 
in the past year. In FY 2025, NICS denied 9,163 transfers based on a 
person being an unlawful user of or addicted to a controlled substance. 
Of these, 8,947 were ultimately denied a firearm. See Table 1, above, 
and accompanying text. Of these 8,947 denials, 4,560, or about 51 
percent (51 percent = 4,560/8,947 * 100) were based on admissions of 
single use or single possession, a single failed drug test, or a single 
misdemeanor drug conviction within the past year as an indication of 
regular use or possession. See Table 2, above.
    The 4,560 denials based on single-incident inferences included 196 
delayed denials in which the person received a firearm. ATF did not 
pursue any of these denials for further criminal investigation, 
firearms forfeiture, or prosecution. ATF referred only 80 delayed 
denials based on single-use inferences (a single misdemeanor drug 
conviction). This data and ATF guidelines and practices demonstrate 
both the rarity of drug-related enforcement actions and the de facto 
standard for recurring or regular use that is already applied to most 
delayed denials in the field. Because, as a practical matter, most 
delayed denials do not result in an individual failing to receive a 
firearm on the basis of section 922(g)(3), amending the regulations as 
proposed in this rule to clarify the scope of section 922(g)(3) will 
have only de minimis impacts for individuals' ability to receive a 
firearm pursuant to a delayed denial and exercise their Second 
Amendment rights.
    In the context of standard denials, however, the amended regulatory 
definition will confer a qualitative benefit to persons who would have 
been denied the opportunity to purchase a firearm under the current, 
unamended regulatory definition. As noted above, NICS reported 9,163 
denials under 18 U.S.C. 922(g)(3) in FY 2025, 8,817 of which were 
standard denials in which the person did not receive the firearm on the 
basis of unlawfully using controlled substances. See Table 1, above. Of 
these cases, 4,284 were denied on the basis of inferences due to a 
single admission of use, single admission of possession, single failed 
drug test during the past year, or single misdemeanor drug conviction. 
See Table 2, above. Adding to this number the 80 delayed denials based 
on a single misdemeanor conviction results in 4,364 persons who were 
unable to receive or retain a firearm based on single-use inferences. 
These 4,364 persons would thus be the group that would receive 
qualitative benefits from this rule, in that they would now--contrary 
to current practice--be able to purchase firearms during the same year 
in which they had only one drug-related incident giving rise to an 
inference of regular use or possession. Assuming that this annual 
number of standard

[[Page 2705]]

denials based on single-use inferences would continue at a similar rate 
int the future without this rule, then over the next ten years, this 
rule will prevent erroneously denying--as standard denials based on 
single-use inferences--approximately 42,840 transfers.
    This IFR will also likely lead to benefits to the public in the 
form of greater clarity, and to benefits in the form of less ambiguity 
for those who enforce and administer the various federal law provisions 
in the GCA and its implementing regulations. ATF is adding new 
provisions to clarify that a person is not an unlawful user if the 
person has ceased regularly using the substance or if the person uses a 
controlled substance in an isolated or sporadic manner, with added 
language to indicate that a single incident is not sufficient for a 
denial under 18 U.S.C. 922(g)(3). The rule also removes the examples 
from the definition, which have caused confusion about whether a single 
incident of using or possessing a controlled substance could create an 
inference of regular use.
    These provisions better align with field enforcement, judicial 
precedent, and administrative guidance. Thus, the disconnect between 
the current regulatory definition and these other indicia of the 
meaning of section 922(g)(3) will no longer be a potential source of 
confusion for the public.
3. Costs
    ATF estimates that this rule will not create any compliance 
burdens, either qualitative or quantitative. This is because ATF has 
already adopted, as a practical matter, the changes discussed in this 
rule in its enforcement actions,\27\ and because the changes also align 
with longstanding court decisions that require regular unlawful use of 
a controlled substance over an extended period of time. Although ATF 
practices have changed in anticipation of this rule, and although ATF 
anticipates that NICS practices for background checks will also change 
as a result of the rule, these changes would not present a public cost 
or burden. Instead, some persons who currently cannot purchase a 
firearm during the same year in which they have a drug incident would 
simply be able to purchase the firearm, without any material change to 
the public in how NICS operates.
---------------------------------------------------------------------------

    \27\ In 2026, ATF also stopped referring delayed denials based 
on single misdemeanor drug convictions.
---------------------------------------------------------------------------

    However, this rule's change could potentially result in an 
increased risk to public safety because some persons who have a record 
of only one drug offense in the relevant time period could be regular 
drug users that just do not have records of more offenses. Under the 
current regulatory definition, such persons would receive standard NICS 
denials and would not be able to purchase a firearm in the same year in 
which they have such an incident. Under the proposed regulatory 
definition, by contrast, they would be able to. This rule could thus 
result in an increased risk that such persons would be under the 
influence of drugs when purchasing and thereafter possessing their 
firearm,\28\ representing a risk to public safety. However, as noted 
above, ATF estimates this increased risk to be de minimis. Of the 
aforementioned 34,036,267 entries in the NICS Index database, 54,136 
were entries for being an unlawful user of or addicted to a controlled 
substance (including denials not based on single-use inferences), which 
represents only 0.16 percent of prohibiting entries. In addition, the 
population that would now be able to purchase firearms in this context 
would be 4,284 persons per year--i.e., those persons who would have 
received standard denials involving single-incident cases without this 
rule. An unknown portion of this population would represent the 
magnitude of potential risk to public safety. ATF believes that the 
costs associated with such circumstances would be vanishingly small 
because ATF's enforcement experience has shown that a pattern of 
controlled substance arrests, controlled substance convictions, or 
other incidents outlined in the amended regulatory definition--not a 
single example of such incidents--is a more accurate indicator of 
whether a person is a habitual user of controlled substances.
---------------------------------------------------------------------------

    \28\ Substance abuse does not necessarily result in intoxication 
or impairment at any given moment in time. From a clinical 
standpoint, impairment is episodic and substance-specific. However, 
because the possibility that regular unlawful drug use could result 
in intoxication, impairment, or other effects on judgment, Congress 
was concerned about the risk of such use to public safety if the 
person also had a firearm. By making the changes in this rule, that 
risk could be increased.
---------------------------------------------------------------------------

4. Regulatory Alternatives
    ATF considered three alternatives in formulating this rule: 
continuing the status quo without changing the existing regulatory 
definition; issuing guidance to those who rely on the current 
provision; or revising the existing regulation.
Option 1: Continuing the Status Quo of Maintaining the Existing 
Inferences
    This is also known as the no-action alternative. ATF considered 
this alternative but, in light of (1) court cases over the past 20 
years that have found a single incident of drug use to be insufficient 
in most cases, (2) ATF's experience in terms of prosecutors declining 
to pursue such cases, and (3) the conflicting inferences in the 
regulation that have caused differing applications, ATF concluded this 
option would continue to impose a qualitative burden on the public 
without increasing public safety--i.e., the level of public safety 
related to this prohibition's definition would remain the same as it 
currently is. ATF considers it inappropriate to retain the existing 
inference examples in the regulatory definition because a single recent 
incident of using or possessing a controlled substance is insufficient 
evidence upon which to base an administrative forfeiture or to deem a 
person prohibited under the GCA as an unlawful user. These inferences 
no longer align with ATF practice and guidance, or the weight of court 
decisions issued over the past 20 years, and they create confusion and 
inconsistency between different ways the regulatory inferences are 
applied. Classifying individuals as prohibited persons on the basis of 
a single unlawful use of a controlled substance is also potentially 
unconstitutional under the Second Amendment. As a result, ATF 
determined that it should take some action to resolve these issues.
Option 2: Guidance
    ATF considered issuing guidance to the NICS Section and other 
Department elements charged with administering or enforcing 18 U.S.C. 
922(g)(3), as well as state, local, and tribal partners that may also 
rely upon 27 CFR 478.11. The guidance would set out the court decisions 
and ATF's practices that have aligned with those decisions since at 
least 2018. In addition, it would inform the enforcing elements that 
ATF's policy and statutory interpretation position is that a single 
incident is no longer sufficient to meet the statutory prohibition and 
request that the elements adjust their internal guidance and their 
enforcement practices to align. ATF believes providing guidance to the 
other elements is an important option, especially in the short term, 
and will be working with the FBI on this change. ATF believes that 
guidance can often contain more detailed explanations of how to apply 
statutory or regulatory terms than can a regulation. However, because 
the existing regulatory definition contains the problematic inference 
examples, ATF determined that the guidance option would not suffice as 
a complete replacement for a

[[Page 2706]]

rulemaking that removes the inference examples. Guidance should provide 
more details and interpret regulatory provisions, not conflict with 
them or obviate portions of them. Without the regulatory change, many 
people would still believe they have to apply these inferences or use 
these examples. A regulation is treated as more binding than guidance, 
even on agencies, and reaches other organizations that might not know 
to search out guidance or that guidance changing the regulation exists.
Option 3: Rulemaking (Proposed Alternative)
    The inferences included in the definition of unlawful user are 
contained in a regulation. To remove them from that regulation requires 
a rulemaking. The existing definition's inference examples conflict 
with court decisions and enforcement practice, so retaining them in the 
regulatory definition creates potential confusion and inconsistency, 
and may cause persons to be denied firearms when they should not be. 
Revising, in relevant part, the definition of an unlawful user to 
specifically include that the person must use the controlled substance 
regularly over an extended period of time, and to remove the inference 
examples entirely, reduces confusion for those enforcing section 
922(g)(3) and for persons possessing, or desiring to possess, firearms. 
This is especially important for the future so that members of the 
public are not confused when they consult ATF's regulations. In 
addition, this option complies with sound regulatory drafting 
principles by deleting no-longer-applicable examples and bringing the 
regulations into alignment with years of case law and previously 
changed portions of ATF internal guidance and practices. ATF is issuing 
this interpretive rule to effectively stop people from being denied 
firearms based on the existing regulation's content. A rulemaking--not 
a different option--is the most effective way to achieve this goal.

C. Executive Order 14192

    Executive Order 14192 (Unleashing Prosperity Through Deregulation) 
requires an agency, unless prohibited by law, to identify at least ten 
existing regulations to be repealed or revised when the agency publicly 
proposes for notice and comment or otherwise promulgates a new 
regulation that qualifies as an Executive Order 14192 regulatory action 
(defined in OMB Memorandum M-25-20 as a final significant regulatory 
action as defined in section 3(f) of Executive Order 12866 that imposes 
total costs greater than zero). In furtherance of this requirement, 
section 3(c) of Executive Order 14192 requires that any new incremental 
costs associated with such new regulations must, to the extent 
permitted by law, also be offset by eliminating existing costs 
associated with at least ten prior regulations. Although this IFR is a 
significant regulatory action as defined by Executive Order 12866 
because it raises a novel policy issue, it does not impose total costs 
greater than zero. This rule provides qualitative benefits to the 
public by clarifying an existing definition and ensuring the definition 
aligns better with court cases that have interpreted it, thereby 
reducing the number of individuals erroneously denied the option of 
purchasing firearms. It imposes no costs. This IFR therefore qualifies 
as an Executive Order 14192 deregulatory action (defined by OMB 
Memorandum M-25-20 as a final action that imposes total costs less than 
zero).

D. Executive Order 14294

    Executive Order 14294 (Fighting Overcriminalization in Federal 
Regulations) requires agencies promulgating regulations with criminal 
regulatory offenses potentially subject to criminal enforcement to 
explicitly describe the conduct subject to criminal enforcement, the 
authorizing statutes, and the mens rea standard applicable to each 
element of those offenses. This IFR does not create a criminal 
regulatory offense and is thus exempt from Executive Order 14294 
requirements.

E. Executive Order 13132

    This IFR does not have substantial direct effects on the states, 
the relationship between the federal government and the states, or the 
distribution of power and responsibilities among the various levels of 
government. Therefore, in accordance with section 6 of Executive Order 
13132 (Federalism), the Acting Director, ATF, has determined that this 
rule does not impose substantial direct compliance costs on state and 
local governments, preempt state law, or meaningfully implicate 
federalism. It thus does not warrant preparing a federalism summary 
impact statement.

F. Executive Order 12988

    This IFR meets the applicable standards set forth in sections 3(a) 
and 3(b)(2) of Executive Order 12988 (Civil Justice Reform).

G. Regulatory Flexibility Act

    Under the Regulatory Flexibility Act (``RFA''), 5 U.S.C. 601-12, 
agencies are required to conduct a regulatory flexibility analysis of 
any rule subject to notice-and comment-rulemaking requirements unless 
the agency head certifies, including a statement of the factual basis, 
that the rule will not have a significant economic impact on a 
substantial number of small entities. Small entities include certain 
small businesses, small not-for-profit organizations that are 
independently owned and operated and are not dominant in their fields, 
and governmental jurisdictions with populations of less than 50,000.
    The Acting Director, ATF, certifies, after consideration, that this 
IFR does not have a significant economic impact on a substantial number 
of small entities. This rule is deregulatory and does not impose any 
additional costs or burdens on any party, including members of the 
public or regulated businesses. Instead, the provisions of this rule 
primarily offer clarity on existing policy, reduce qualitative burdens 
on current and prospective firearm owners, and result in fewer 
background check denials, thereby permitting small businesses to 
complete more firearm sales.
    Although reducing denials may result in additional sales for some 
small businesses engaged in dealing firearms, the number of denials 
based on 18 U.S.C. 922(g)(3), as explained in section III.B of this 
preamble, is small enough that ATF anticipates that this increased 
revenue will not have a significant economic impact on a substantial 
number of such businesses. In addition, this rule is an interpretive 
rule that is not required to proceed through notice and comment, see 
section III.A of this preamble, so it is exempt from the requirement to 
complete a regulatory flexibility analysis.

H. Small Business Regulatory Enforcement Fairness Act of 1996

    This IFR does not have a significant economic impact on a 
substantial number of small entities under the Small Business 
Regulatory Enforcement Fairness Act of 1996, because it imposes no 
additional costs or burdens on any party, including members of the 
public or regulated businesses. Instead, the rule's provisions 
primarily offer clarity on existing policy, reduce qualitative burdens 
on current and prospective owners of firearms, and result in fewer 
background check denials.

I. Unfunded Mandates Reform Act of 1995

    This IFR does not include a federal mandate that might result in 
the aggregate expenditure by state, local, and tribal governments, or 
by the

[[Page 2707]]

private sector, of $100 million or more in any one year, and it will 
not significantly or uniquely affect small governments. Therefore, ATF 
has determined that no actions are necessary under the provisions of 
the Unfunded Mandates Reform Act of 1995.

J. Paperwork Reduction Act of 1995

    Under the Paperwork Reduction Act of 1995 (``PRA''), 44 U.S.C. 
3501-3521, agencies are required to submit to OMB, for review and 
approval, any information collection requirements a rule creates or any 
impacts it has on existing information collections. As defined in 5 CFR 
1320.3(c), an information collection includes any reporting, record-
keeping, monitoring, posting, labeling, or other similar actions an 
agency requires of the public. This IFR does not create any new 
information collection requirements, or impact any existing ones, 
covered under the PRA.

K. Congressional Review Act

    Pursuant to the Congressional Review Act, 5 U.S.C. 801 et seq., 
OMB's Office of Information and Regulatory Affairs has determined that 
this IFR does not meet the criteria in 5 U.S.C. 804(2) to constitute a 
major rule. This rule is not a major rule because it will not result in 
an annual effect on the economy of $100 million or more; a major 
increase in costs or prices; or significant adverse effects on 
competition, employment, investment, productivity, innovation, or on 
the ability of United States-based enterprises to compete with foreign-
based enterprises in domestic and export markets.

IV. Public Participation

A. Comments Sought

    ATF requests comments on the IFR from all interested persons. ATF 
specifically requests comments on the clarity of this IFR and how it 
may be made easier to understand. In addition, ATF requests comments on 
the costs or benefits of the rule and on the appropriate methodology 
and data for calculating those costs and benefits.
    All comments must reference this document's RIN 1140-AB03 and, if 
handwritten, must be legible. If submitting by mail, you must also 
include your complete first and last name and contact information. If 
submitting a comment through the federal e-rulemaking portal, as 
described in section IV.C of this preamble, you should carefully review 
and follow the website's instructions on submitting comments. Whether 
you submit comments online or by mail, ATF will post them online. If 
submitting online as an individual, any information you provide in the 
online fields for city, state, zip code, and phone will not be publicly 
viewable when ATF publishes the comment on https://www.regulations.gov. 
However, if you include such personally identifiable information 
(``PII'') in the body of your online comment, it may be posted and 
viewable online. Similarly, if you submit a written comment with PII in 
the body of the comment, it may be posted and viewable online. 
Therefore, all commenters should review section IV.B of this preamble, 
``Confidentiality,'' regarding how to submit PII if you do not want it 
published online.
    ATF may not consider, or respond to, comments that do not meet 
these requirements or comments containing excessive profanity. ATF will 
retain comments containing excessive profanity as part of this 
rulemaking's administrative record but will not publish such documents 
on https://www.regulations.gov. ATF will treat all comments as 
originals and will not acknowledge receipt of comments. In addition, if 
ATF cannot read your comment due to handwriting or technical 
difficulties and cannot contact you for clarification, ATF may not be 
able to consider your comment.
    ATF will carefully consider all comments, as appropriate, received 
on or before the closing date.

B. Confidentiality

    ATF will make all parts of all comments meeting the requirements of 
this section, whether submitted electronically or on paper, and except 
as described below, available for public viewing on the internet 
through the federal e-rulemaking portal, and subject to the Freedom of 
Information Act (5 U.S.C. 552). Commenters who submit by mail and who 
do not want their name or other PII posted on the internet should 
submit their comments with a separate cover sheet containing their PII. 
The separate cover sheet should be marked with ``CUI//PRVCY'' at the 
top to identify it as protected PII under the Privacy Act. Both the 
cover sheet and comment must reference this RIN 1140-AB03. For comments 
submitted by mail, information contained on the cover sheet will not 
appear when posted on the internet, but any PII that appears within the 
body of a comment will not be redacted by ATF and may appear on the 
internet. Similarly, commenters who submit through the federal e-
rulemaking portal and who do not want any of their PII posted on the 
internet should omit such PII from the body of their comment or in any 
uploaded attachments. However, PII entered into the online fields 
designated for name, email, and other contact information will not be 
posted or viewable online.
    A commenter may submit to ATF information identified as proprietary 
or confidential business information by mail. To request that ATF 
handle this information as controlled unclassified information 
(``CUI''), the commenter must place any portion of a comment that is 
proprietary or confidential business information under law or 
regulation on pages separate from the balance of the comment, with each 
page prominently marked ``CUI//PROPIN'' at the top of the page.
    ATF will not make proprietary or confidential business information 
submitted in compliance with these instructions available when 
disclosing the comments that it receives, but it will disclose that the 
commenter provided proprietary or confidential business information 
that ATF is holding in a separate file to which the public does not 
have access. If ATF receives a request to examine or copy this 
information, it will treat it as any other request under the Freedom of 
Information Act (5 U.S.C. 552). In addition, ATF will disclose such 
proprietary or confidential business information to the extent required 
by other legal process.

C. Submitting Comments

    Submit comments using either of the two methods described below 
(but do not submit the same comment multiple times or by more than one 
method). Hand-delivered comments will not be accepted.
     Federal e-rulemaking portal: ATF recommends that you 
submit your comments to ATF via the federal e-rulemaking portal at 
https://www.regulations.gov by following the instructions on the web 
page. Comments will be posted within a few days of being submitted. 
However, if large volumes of comments are being processed 
simultaneously, your comment may not be viewable for up to several 
weeks. Please keep the comment tracking number that is provided after 
you have successfully uploaded your comment.
     Mail: Send written comments to the address listed in the 
ADDRESSES section of this document. Written comments must appear in 
minimum 12-point font size, include the commenter's first and last name 
and full mailing address, and may be of any length. See also section 
IV.B of this preamble, ``Confidentiality.''

[[Page 2708]]

D. Request for Hearing

    Any interested person who desires an opportunity to comment orally 
at a public hearing should submit his or her request, in writing, to 
the Acting Director of ATF within the 180-day comment period. The 
Acting Director, however, reserves the right to determine, in light of 
all circumstances, whether a public hearing is necessary.

Disclosure

    Copies of this IFR and the comments received in response to it are 
available through the federal e-rulemaking portal, at https://www.regulations.gov (search for RIN 1140-AB03).

List of Subjects in 27 CFR Part 478

    Administrative practice and procedure, Arms and munitions, Exports, 
Freight, Imports, Intergovernmental relations, Law enforcement 
officers, Military personnel, Penalties, Reporting and record-keeping 
requirements, Research, Seizures and forfeitures, Transportation.

    For the reasons discussed in the preamble, ATF amends 27 CFR part 
478 as follows:

PART 478--COMMERCE IN FIREARMS AND AMMUNITION

0
1. The authority citation for 27 CFR part 478 continues to read as 
follows:

    Authority:  5 U.S.C. 552(a); 18 U.S.C. 847, 921-931; 44 U.S.C. 
3504(h).


0
2. Amend Sec.  478.11 by revising the definition of ``Unlawful user of 
or addicted to any controlled substance'' to read as follows:


Sec.  478.11   Meaning of terms.

* * * * *
    Unlawful user of or addicted to any controlled substance. (1) A 
person who uses a controlled substance and demonstrates a pattern of 
compulsively using the controlled substance, characterized by impaired 
control over use, is addicted to a controlled substance.
    (2) A person who regularly uses a controlled substance over an 
extended period of time continuing into the present, without a lawful 
prescription or in a manner substantially different from that 
prescribed by a licensed physician, is an unlawful user of a controlled 
substance.
    (i) Such unlawful use is not limited to using a controlled 
substance on a particular day, or within a matter of days before 
shipping, transporting, possessing, or receiving a firearm. Rather, 
unlawful use requires evidence that the person has unlawfully used the 
substance with sufficient regularity and recency to indicate that the 
individual is actively engaged in such conduct. A person may be an 
unlawful current user of a controlled substance even though the 
substance is not being used at the precise time the person seeks to 
acquire, ship, transport, receive, or possess the firearm.
    (ii) A person is not an unlawful user of a controlled substance if 
the person has ceased regularly unlawfully using the substance, or if 
the person's unlawful use is isolated or sporadic or does not otherwise 
demonstrate a pattern of ongoing use. A person is also not an unlawful 
user if the person, while using a lawfully prescribed controlled 
substance, deviates slightly or immaterially from the instructions of 
the prescribing physician.
* * * * *

Daniel Driscoll,
Acting Director.
[FR Doc. 2026-01141 Filed 1-20-26; 11:15 am]
BILLING CODE 4410-FY-P