Franklin Armory Antithesis: ATF Reversal Leads to 5.56 Recall

The regulatory saga surrounding Franklin Armory's Antithesis firearm has taken another unexpected turn. Just days after our previous post, where we shared the news about Antithesis being available, and mere days after the company began selling 5.56×45mm NATO versions of their controversial short-barreled firearm, the ATF has stepped in to request voluntary returns, prompting Franklin Armory to offer full refunds on these specific models.

The Legal Foundation

The Antithesis represents Franklin Armory's ambitious attempt to circumvent National Firearms Act (NFA) regulations through careful interpretation of federal statutes. This stock-equipped, short-barreled weapon was engineered to fire both single-projectile and multi-projectile ammunition—including .410 shotshells, slugs, and .45 Colt rounds—a design feature that became crucial to its regulatory classification battle.

The legal argument hinges on the precise wording of 26 U.S.C. § 5845(c), which defines a rifle as a shoulder-fired weapon "designed… to fire only a single projectile through a rifled bore for each single pull of the trigger." Franklin Armory's position was straightforward: since the Antithesis can fire multi-projectile ammunition like .410 shotshells, it cannot be classified as a "rifle" and therefore falls outside the short-barreled rifle (SBR) category under the NFA. This contrasts with the shotgun definition, which encompasses smoothbore weapons that may fire "a number of projectiles (ball shot) or a single projectile."

Court Victory and Settlement

After debuting in 2018 and enduring years of regulatory uncertainty, Franklin Armory achieved a significant legal breakthrough this year. On February 18, 2025, U.S. District Judge Daniel M. Traynor (District of North Dakota) delivered a decisive victory in FRAC & Franklin Armory v. Garland (later captioned v. Bondi), granting summary judgment for FRAC and Franklin Armory and overturning ATF's previous misclassifications of both the Reformation and Antithesis firearms.

Judge Traynor's ruling was unambiguous in its reasoning:

      Franklin Armory designed the Antithesis to fire multiple kinds of rifle ammunition. The weapon does not fire only a single projectile. Firing multiple projectiles is not incidental or a by-product. The Antithesis is a square peg and calling it round will not change how it fits into the round hole of these statutes. Therefore, ATF exceeded its authority by not giving the plain meaning to the words of the statute.

The settlement's impact was formalized in an ATF open letter dated August 29, 2025, which rescinded a 2019 Reformation letter and addressed both firearms. The letter specifically described the Antithesis as utilizing "a 14.5-inch rifled barrel to fire .410 bore shotshells and slugs, in addition to .45 Colt cartridges" and formally acknowledged that its previous classification had been vacated.

The agreement's implications were far-reaching:

      As a result of the Agreement, the Antithesis is not a rifle, short-barreled rifle, nor is it an NFA firearm; therefore, (i) no NFA forms are necessary to sell, transfer, transport, deliver, or otherwise deal in or possess the Antithesis, and (ii) no ATF Form 5320.20, Application to Transport Interstate or to Temporarily Export Certain National NFA Firearms, is necessary to transport the Antithesis across state lines because the firearm is not subject to 18 U.S.C. § 922(a)(4) or (b)(4).

The 5.56 Complication

However, the regulatory clarity proved short-lived. Franklin Armory's decision to market a 5.56×45mm NATO variant of the Antithesis on September 17, 2025, immediately drew ATF scrutiny. The agency responded with a clarifying statement on X that fundamentally challenged the scope of the settlement:

         On August 29, 2025, ATF issued an open letter reclassifying Franklin Armory's Reformation and Antithesis. The open letter implemented a settlement agreement, which classified these weapons as "firearms" under the Gun Control Act but not subject to the controls of the NFA. The open letter only applies to the two models listed in the letter, in the specific configuration that was the subject of the settlement agreement. Other short-barreled firearms are not covered by the settlement agreement, even if they are being branded as "Reformation" or "Antithesis" firearms.

The ATF's position becomes clearer when examining their August letter, which specifically noted:

     Separately, FATD examined the Antithesis firearm for classification under the GCA and the NFA. The Antithesis is a type of firearm that utilizes a 14.5-inch rifled barrel to fire .410 bore shotshells and slugs, in addition to .45 Colt cartridges. As such, FATD classified the Antithesis as a shortbarreled rifle under both the GCA and the NFA. This classification was vacated.

The agency's interpretation appears to be that the settlement's protections apply exclusively to the .410/.45 LC configuration that was the subject of the original litigation. The 5.56×45mm version, which fires only single projectiles, would not benefit from the multi-projectile argument that formed the foundation of Franklin Armory's legal victory.

Company Response and Recall

Faced with this regulatory challenge, Franklin Armory has taken a defensive posture. The company issued a statement explaining their situation:

      Last night, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) requested that we voluntarily bring back all 5.56 caliber Antithesis firearms in advance of the agency issuing a new classification. We were surprised by this in light of the U.S. District Court's ruling in FRAC v. Bondi. Out of an abundance of caution and for the well-being of consumers, dealers, and distributors, we are voluntarily requesting all of our customers to return their 5.56 caliber Antithesis firearms for a full refund. We encourage customers who have taken possession of an Antithesis firearm to contact Franklin Armory Customer service for an RMA (Return Merchandise Authorization) and shipping label. This return does not affect Reformation, the .410/45LC Antithesis, or any other firearm made by Franklin Armory.

The company emphasized that this recall is limited to the 5.56 models and does not impact their other firearms, including the original .410/.45 LC Antithesis that was central to their court victory.

Ongoing Legal Battle

This latest development illustrates the complex interplay between innovative firearm design and federal regulations. While Franklin Armory achieved a significant legal precedent with their original Antithesis design, the ATF's interpretation suggests that regulatory compliance depends heavily on specific configurations and intended ammunition types.

The continuing drama surrounding the Antithesis highlights the ongoing tensions between manufacturers seeking to innovate within existing legal frameworks and regulatory agencies tasked with enforcing federal firearms laws. As Franklin Armory has indicated their intention to continue fighting these classifications, this case will likely remain a closely watched example of how statutory interpretation shapes the firearms industry.