Engraving receiver?

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870Mike
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Engraving receiver?

Post by 870Mike » Sat Jul 06, 2013 10:43 pm

I'm in the process of building an SBS. I was told by a person with a manufacturer's license that the existing "engraving" on the receiver (Remington Arms, Ilion NY, Ser. #, etc.) was adequate and that I wasn't required to engrave the trust name, city, state on mine after assembly. He cited a particular page of the ATF regs., but I didn't write it down.

Can anyone tell me where it's written in the ATF manual that engraving is/is not required?
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tony k
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Re: Engraving receiver?

Post by tony k » Sun Jul 07, 2013 10:25 am

Look at the top of the Form 1: It is an "Application to Make and Register a(n NFA) Firearm."

That means the applicant is the maker of record, of the NFA item. It is entered into the NFA Registry under the name of the applicant as maker of record. If, instead, you purchase a factory-built NFA item like a Colt M16, it is listed under "Colt" in the NFA Registry.

The relevant federal law is from Title 27 - Alcohol, Tobacco Products and Firearms, Code of Federal Regulations:

27 CFR 479.102 - How must firearms be identified?

(a) You, as a manufacturer, importer, or maker of a firearm, must legibly identify the firearm as follows:
(1) By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or placed on the frame or receiver thereof an individual serial number. The serial number must be placed in a manner not susceptible of being readily obliterated, altered, or removed, and must not duplicate any serial number placed by you on any other firearm. For firearms manufactured, imported, or made on and after January 30, 2002, the engraving, casting, or stamping (impressing) of the serial number must be to a minimum depth of .003 inch and in a print size no smaller than 1/16 inch; and
(2) By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed), or placed on the frame, receiver, or barrel thereof certain additional information. This information must be placed in a manner not susceptible of being readily obliterated, altered or removed. For firearms manufactured, imported, or made on and after January 30, 2002, the engraving, casting, or stamping (impressing) of this information must be to a minimum depth of .003 inch. The additional information includes:
(i) The model, if such designation has been made;
(ii) The caliber or gauge;
(iii) Your name (or recognized abbreviation) and also, when applicable, the name of the foreign manufacturer or maker;
(iv) In the case of a domestically made firearm, the city and State (or recognized abbreviation thereof) where you as the manufacturer maintain your place of business, or where you, as the maker, made the firearm;


As another example, here is a rejection cover letter from NFA Branch. This Form 1 was rejected because the intended engraving did not meet federal law. If engraving was not required under federal law, how could incorrect engraving be a legal basis for rejection of the Form 1?

Image

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870Mike
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Re: Engraving receiver?

Post by 870Mike » Sun Jul 07, 2013 10:55 am

Thanks. Interesting, but still slightly confused...if I'm installing a factory 14" barrel on a previously "legal" 18" Rem. 870 (this is the extent of my conversion), am I the "maker" or is Remington? And do the rules apply differently to me (Joe Average Citizen) vs. an individual with a manufacturer's license/FFL?
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Re: Engraving receiver?

Post by tony k » Sun Jul 07, 2013 11:25 am

870Mike wrote:Thanks. Interesting, but still slightly confused...if I'm installing a factory 14" barrel on a previously "legal" 18" Rem. 870 (this is the extent of my conversion), am I the "maker" or is Remington? And do the rules apply differently to me (Joe Average Citizen) vs. an individual with a manufacturer's license/FFL?
Again, if the law requires you to file a Form 1, that means you intend to "make" an NFA item.

Prior to installing the 14" barrel, the firearm was not listed in the National Firearms Act Registry. By filing a Form 1, you are applying to "make" an NFA item and have it entered in the NFA Registry. When the Form 1 is approved, it is entered into the Registry, listing you as the "maker."

If you purchase a firearm which is already listed in the NFA Registry, you are not "making" anything, and thus you apply to transfer it from the current registered owner to you, via a Form 4. There is no need to engrave it further, because you are not the "maker."

Read the law above. It lists both "manufacturers," which federal law defines as holders of Class 07 manufacturing licenses, and "makers," who are unlicensed individuals applying to "make" an NFA item via a Form 1.

I highlighted the "maker" references in red. You must do whatever federal law requires of a "maker."

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870Mike
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Re: Engraving receiver?

Post by 870Mike » Sun Jul 07, 2013 11:46 am

Great info, thanks much.
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Re: Engraving receiver?

Post by Mr. Smith » Sun Jul 07, 2013 9:36 pm

I think that the person, with the manufacturer’s license that told Mike that an engraving wasn’t necessary must have misunderstood something. Especially when he said that the “existing” engraving would suffice. I think that must have thought that Mike was transferring a SBS which would have already had an existing engraving from the “maker.”

Of course the person with the manufacturer’s license could also have just been wrong!
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Re: Engraving receiver?

Post by g34man » Mon Jul 08, 2013 1:20 pm

If you engrave check http://ajimachining.com/ . I think he charges $30 for engraving and he is in Hialeah. Call him before you go to give him the engraving information.

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