Updated August 8, 2026. Educational information only — not legal advice. Verify current law before acting.
If you hold — or are working toward — the FFL03 + COE combination, the last eighteen months of litigation have quietly reshaped the landscape around your collection. Here’s what the recent wave of decisions means specifically for California curio and relic collectors.
Nguyen v. Bonta: your old exemption is now everyone’s rule
For years, one of the marquee perks of the FFL03 + COE combo was the statutory exemption from California’s one-handgun-per-30-days limit for C&R handguns. In June 2025, the Ninth Circuit struck the one-in-30 law entirely in Nguyen v. Bonta. That levels the field for ordinary buyers — but for collectors it removes a paperwork worry altogether: assembling a collection no longer requires pacing purchases against a state meter, exemption or not.
Rhode v. Bonta: the ammunition regime takes a hit
In July 2025, the Ninth Circuit held California’s ammunition background-check scheme unconstitutional in Rhode v. Bonta. Collectors of milsurp rifles — who tend to buy surplus ammunition in bulk and in calibers local shops rarely stock — have felt this regime’s friction more than most. Keep in mind the state has continued to explore its legal options, so confirm the current rules before ordering; and remember that the FFL03 + COE combo already provided a lawful direct-shipment path for ammunition even under the old regime — another reason the credential pays for itself.
Wolford and Baird: carry law in motion
The Supreme Court’s June 2026 decision in Wolford v. Lopez (carry on private property open to the public) and the pending en banc fight in Baird v. Bonta (open carry) don’t touch your collector credentials directly — an FFL03 is an acquisition license, not a carry permit. But many collectors are also CCW holders, and the practical rules about where you may carry are changing quarter by quarter. Two cautions: SB2’s private-property rule is still on the books until May v. Bonta resolves, and open carry remains illegal in urban counties despite the January panel ruling. Our dedicated articles on Wolford and Baird have the details.
Duncan v. Bonta: the limit that stayed
Not everything moved in the collector’s favor. In March 2025 the en banc Ninth Circuit upheld California’s ban on magazines over ten rounds in Duncan v. Bonta. For collectors of C&R-era firearms that shipped with standard magazines larger than ten rounds, the ban’s restrictions remain in effect, and the fight now points toward the Supreme Court.
What hasn’t changed for collectors
Amid the litigation churn, the fundamentals of C&R collecting in California are stable: the FFL03 still requires the COE to unlock its California benefits; interstate C&R acquisitions still must be reported through CFARS within five days; the bound book is still a federal requirement; and the collector waiting-period exemption for C&R transactions still applies. If you’re new to all of this, our step-by-step course walks through the whole process: How to Get Your FFL03/COE.
Sources: Nguyen v. Bonta analysis • Second Amendment Law Center California case tracker • Wolford v. Lopez, SCOTUSblog • Baird v. Bonta panel opinion
This article is educational content from CAGUNS Resource Hub and is not legal advice. Consult a qualified attorney about your specific situation.
What the Community Is Saying
Collectors on CAguns spent much of 2026 working out what the year's changes actually meant for an 03 FFL and a COE. Two threads carry most of the useful material, and between them they correct the single most common misunderstanding in this corner of California law.
The exemption only cuts one way
This is the correction worth internalizing. An FFL03 plus COE exempts you from the new three-per-thirty-days purchase cap. It does not exempt you from California's five-transaction annual limit on private party sales — because an 03 is a collector's license, not a dealer's license. Members were sympathetic about the confusion, since the exemption genuinely exists on the buying side and genuinely does not on the selling side.
How collectors actually liquidate
A member liquidating roughly twenty C&R guns got three competing answers: consignment through established GunBroker sellers, direct sales to other 03/COE holders for cash to avoid commissions, or the CAguns marketplace if you aren't in a hurry. The most useful contribution was procedural — at a dealer running these transfers, C&R items with valid 03/COE paperwork go home the same day, while everything else sits through the standard ten-day wait or longer.
The COE application rule that quietly changed
Worth knowing if you have applied recently and been rejected. In March 2026 an Office of Administrative Law determination invalidated the DOJ's practice of requiring an FFL-03 number on COE applications, treating it as an underground regulation. Members reported concrete results: one applicant rejected for missing FFL-03 information resubmitted citing the determination and was approved overnight; another applied for both at once and had the COE in a day. Note the mechanism carefully — this was an administrative determination, not a court ruling, which is a distinction a lot of secondhand coverage got wrong.
Plus the COE application thread linked inside · CAguns.net
Applied for a COE recently? Post what the DOJ asked you for and how long it took.
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