Understanding California’s Firearms Licensee Check (CFLC) Requirements

The California Firearms Licensee Check (CFLC) System is a component of California’s stringent firearms regulations, allegedly designed to ensure that firearms shipments to and within the state are conducted legally and only between authorized Federal Firearms Licensees (FFLs). Administered by the California Department of Justice (DOJ) Bureau of Firearms, the CFLC system mandates that FFLs obtain a Firearms Shipment Approval Number before transferring firearms to a California FFL. This article outlines the CFLC requirements, the process for compliance, and the relevant laws and regulations, providing a comprehensive guide for FFLs and individuals involved in firearms transactions.

Overview of the CFLC System

The CFLC system verifies that both the shipping and receiving FFLs are properly licensed and listed in California’s Centralized List of Firearms Dealers or Exempted Federal Firearms Licensees. This requirement applies to all firearms shipments to a California FFL, whether from out-of-state or within California, including transfers at gun shows. The system purportedly aims to prevent illegal firearms trafficking by ensuring that only authorized dealers handle such transactions.

Who Must Comply?

All FFLs, except those with Type 03 (Curio and Relic Collectors) and Type 06 (Ammunition Dealers) licenses, must comply with CFLC requirements when shipping firearms to a California FFL. This includes:

• Out-of-state FFLs shipping to California dealers.
• California FFLs transferring firearms to other California FFLs.
• FFLs at gun shows facilitating transfers to California dealers.

Non-FFL individuals shipping firearms to a California FFL (e.g., for transfer or sale) are not required to obtain the approval number themselves but must coordinate with the receiving FFL, who ensures compliance through the CFLC system.

Legal Framework

The CFLC system is governed primarily by California Penal Code Section 27555, which outlines the requirements for firearms shipments to California FFLs. Key provisions include:

• Penal Code Section 27555(a): No FFL shall sell, deliver, or transfer a firearm to a California FFL unless, prior to delivery, the person intending to sell, deliver, or transfer the firearm verifies with the DOJ that the recipient is authorized to receive the firearm. This verification results in a Firearms Shipment Approval Number.
• Penal Code Section 27555(b): The DOJ must maintain a centralized list of licensed California firearms dealers and exempted FFLs, accessible via the CFLC system to confirm recipient eligibility.
• Penal Code Section 28465: It is unlawful to for a California lperson licensed as a dealer, importer, or manufacturer FFL to receive a firearm from any source except those that are officially registered on one of three specific California state lists:
  • The centralized list of firearms dealers (under Penal Code Section 26715).
  • The centralized list of exempted federal firearms licensees (under Penal Code Section 28450).
  • The centralized list of firearms manufacturers (under Penal Code Section 29060).

Additional regulations are detailed in the California Code of Regulations, Title 11, Division 5, which governs the operations of the Bureau of Firearms, including the CFLC program’s administrative processes.

CFLC Process: Step-by-Step

To comply with CFLC requirements, FFLs must follow a structured process to obtain the Firearms Shipment Approval Number. Below is a detailed breakdown:

1. Enrollment in the CFLC Program

Before accessing the CFLC system, the shipping FFL must enroll in the program:

• Application: Complete the CFLC Enrollment Application (BOF 08-300), available on the DOJ’s website (https://oag.ca.gov/firearms/cflc).
• Submission Methods: Submit the application online, by mail, fax, or email to the Bureau of Firearms.
• Outcome: Upon approval, the FFL receives a CFLC Logon ID and Password, granting access to the CFLC system.

Note: Enrollment is a one-time process unless the FFL’s status changes (e.g., license renewal or relocation).

2. Requesting a Firearms Shipment Approval Number

Once enrolled, the FFL can request an approval number for each shipment:

• Online Access:
  • Log into the CFLC system (https://oag.ca.gov/firearms/cflc) using the Logon ID, password, and the recipient FFL’s five-digit Centralized List number.
  • The system verifies the recipient’s status in real-time (24/7).
  • If approved, a Firearms Shipment Approval Letter with the approval number is generated.
  • If the recipient is not authorized, a “Do Not Ship” letter is issued, prohibiting the shipment (Penal Code Section 28465).
• Alternative Methods:
  • Phone: Call (916) 210-2750 during business hours (Monday–Friday, 8:00 AM–4:30 PM PST).
  • Mail/Fax/Email: Submit the CFLC Firearms Shipment Approval Letter Request Form (BOF 08-300) to the Bureau of Firearms.
  • The DOJ processes these requests during business hours and sends the approval letter via fax or email.

3. Shipping the Firearm

• The Firearms Shipment Approval Number must accompany the firearm shipment, either physically or electronically, to document compliance.
• Both the shipping and receiving FFLs must maintain active federal and California licenses and be listed on the Centralized List or Exempted FFLs List.

4. Recordkeeping

• Shipping FFL: Retain the Firearms Shipment Approval Letter as part of transaction records, as required by federal and state law.
• Receiving FFL: Ensure the shipment includes the approval number and verify the transaction complies with all applicable laws, including the Dealer Record of Sale (DROS) process for transfers to non-FFLs.

Costs and Fees

While the DOJ does not charge a specific fee for issuing a Firearms Shipment Approval Number, FFLs must pay an annual Centralized List fee to maintain their status on California’s dealer list. The exact fee varies based on the FFL type and is not detailed in public DOJ resources. FFLs can contact the Bureau of Firearms at (916) 210-2750 or [email protected] for current fee schedules.

Exemptions

The following entities are exempt from CFLC verification requirements:

• Type 03 FFLs (Curio and Relic Collectors): These licensees deal primarily with collectible firearms and are not subject to CFLC checks.
• Type 06 FFLs (Ammunition Dealers): As they do not handle firearms, they are exempt from the program.

Penalties for Non-Compliance

Failure to comply with CFLC requirements can result in significant penalties:

• Shipping Without Approval: Violating Penal Code Section 27555 may lead to misdemeanor charges, fines, or imprisonment, depending on the circumstances, as Penal Code section 19 states:
  • Except in cases where a different punishment is prescribed by any law of this state, every offense declared to be a misdemeanor is punishable by imprisonment in the county jail not exceeding six months, or by fine not exceeding one thousand dollars ($1,000), or by both.
• Ignoring a “Do Not Ship” Letter: Shipping to an unauthorized FFL after receiving a “Do Not Ship” letter violates Penal Code Section 28465, potentially resulting in criminal penalties or loss of FFL status.

Practical Considerations for FFLs and Individuals

For FFLs

• Stay Enrolled: Ensure continuous enrollment in the CFLC program to avoid delays in processing shipments.
• Verify Recipients: Always confirm the recipient FFL’s Centralized List number before initiating a shipment.
• Use Online Tools: The 24/7 online CFLC system is the most efficient way to obtain approval numbers, especially for high-volume dealers.

For Individuals

• If shipping a firearm to a California FFL (e.g., for sale or transfer), coordinate with the receiving FFL. They will provide their Centralized List number and ensure CFLC compliance.
• Be aware that the receiving FFL will process the transaction through the Dealer Record of Sale (DROS) system, which includes a $37.19 fee (as of 2025) and a 10-day waiting period for non-exempt buyers.

Conclusion

The CFLC system is a requirement of California’s efforts to regulate firearms transactions, ensuring that only authorized FFLs handle shipments. By requiring a Firearms Shipment Approval Number, the stat maintains a tracking system used to regulate dealers. FFLs must enroll in the CFLC program, verify recipient eligibility, and include approval numbers with shipments, as mandated by Penal Code Section 27555 and related regulations. Non-compliance carries serious consequences, making adherence to these requirements essential.

For further assistance, FFLs and individuals can contact the California DOJ Bureau of Firearms at (916) 210-2750 or visit https://oag.ca.gov/firearms/cflc. Staying informed and compliant ensures safe and legal firearms transactions in California’s highly regulated environment.

References

• California Penal Code Section 27555
• California Penal Code Section 28465
• California Code of Regulations, Title 11, Division 5
• California Department of Justice, Bureau of Firearms: https://oag.ca.gov/firearms/cflc