We've mentioned the film-prop exception in passing in a couple of other posts without ever unpacking it. It's a narrow provision, but Colorado has an active film industry, so it's worth looking closely at what the text does and does not cover.

The exact text

C.R.S. 18-12-116(3)(g) exempts:

"The manufacture, distribution, transfer, sale, or rental of a specified semiautomatic firearm capable of only firing blanks by, or receipt or purchase of a specified semiautomatic firearm capable of only firing blanks from, a federally licensed firearm dealer, for use solely as a prop for a film, as defined in section 24-48.5-114."

Breaking that down, several conditions work together: the firearm has to be capable of only firing blanks; the listed dealer-side conduct must be performed by a federally licensed firearm dealer, or the receipt or purchase must be from one; the use must be solely as a film prop; and "film" has to match the definition borrowed from Colorado's film-incentive statute.

"Film" is broader than you'd expect

C.R.S. 24-48.5-114(1)(a) — the definition SB25-003 explicitly imports — defines "film" as "any visual or audiovisual work, including, without limitation, a video game, television show, or a television commercial, that contains a series of related images... and that is primarily intended to be either commercially exploited... or for internal industrial, corporate, or institutional use." It excludes obscene material, but otherwise it isn't limited to theatrical movies. Depending on the details, a streaming series, commercial, corporate training video, or video game production may fit the statutory definition. This is also the definition used by Colorado's film-incentive program.

The part that actually matters: "capable of only firing blanks"

This is the qualifier that does the real work, and it's easy to misread. The exception doesn't cover an ordinary SSF merely because it is loaded with blank ammunition for a scene. It covers a firearm that is incapable of firing anything but blanks — a purpose-built or properly modified blank-only firearm, not a conventional AR-pattern rifle or gas-operated pistol loaded with blanks instead of live ammunition.

A conventional semiautomatic firearm that remains mechanically capable of firing live ammunition doesn't stop being "capable" of doing so merely because a production uses blanks or dummy rounds on a particular day. If a production wants to acquire or use a functional SSF, this narrow film-prop exception does not authorize the transaction. Whether another exception or the ordinary purchase pathway covers the precise transaction depends on what is happening — purchase, sale, rental, loan, manufacture, distribution, or another kind of transfer — because the statute does not use identical language for all of them. A production should not assume that a purchaser's eligibility card cures every kind of transaction.

The distinction also matters for film-set safety, which has received intense national attention since the 2021 shooting during production of Rust in New Mexico. A live round discharged from a functional revolver, killing cinematographer Halyna Hutchins and injuring director Joel Souza. That incident did not involve Colorado or SB25-003, and the revolver was not an SSF. It does, however, illustrate why "blank-only prop" and "functional firearm used as a prop" should never be treated as interchangeable terms. The Colorado exemption expressly draws that distinction for a different purpose: determining which transactions are exempt from its SSF restrictions.

What this provision does not answer

This provision is not a comprehensive set-safety rule. It is a narrow exception to SB25-003's restrictions on specified transactions. It does not establish armorer qualifications, firearm-handling protocols, storage practices, or other on-set safety requirements. Other federal, state, local, workplace, location, and industry requirements may apply, and this exception does not displace them.

Bottom line

The film-prop exception is written for blank-only SSFs supplied through the federally licensed dealer structure and used solely as props for productions that fit Colorado's statutory definition of "film." It does not cover a functional SSF merely because it is loaded with blanks on set. And because the law treats different kinds of transactions differently, a production dealing with a functional SSF should confirm the specific purchase, rental, loan, or transfer arrangement with its federally licensed supplier, armorer, and qualified Colorado counsel rather than assuming the ordinary purchaser pathway applies.

As always, we are not lawyers — just Colorado citizens trying to understand the law and share what we learn. The information on this website is for general informational purposes only and does not constitute legal advice, nor does it create an attorney/client relationship. The accuracy, completeness, or currency of the content is not warranted. Your use of content on this website is at your own risk. Consult an attorney about your specific circumstances.