SBR Engraving Discussion

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  • 1slow01Z71

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    Jun 24, 2012
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    Kyle
    For the sake of discussion I know there have been many posts on this subject all over the internet Id like some information from a directly citeable(is that a word?) where for an individual filing a form 1 is required to engrave the firearm. As Ive started to receive my form 1s back Ive been doing a ton of reading on this subject because there is very little information on it pertaining to an individual registering their firearm as a SB whatever.

    To pretext this Im not saying Im right, just simply trying to find someone that can show me where on the ATF site that engraving is required by an individual registering a firearm as a short barrel.

    In the FAQ section for short barrel firearms it mentions nothing about engraving which seems odd to me that they don't at least reference the ATF guidelines for engraving.
    Firearms - Frequently Asked Questions - National Firearms Act (NFA) - Short Barreled Rifles and Shotguns | ATF
    The guidelines for engraving all talk about manufacturers of firearms and how they need to mark them
    Firearms - Guides - Importation & Verification of Firearms, Ammunition and Implements of War - Firearms Verification Overview | ATF
    eCFR ? Code of Federal Regulations
    Some will say that by filing the form 1 YOU are now the manufacturer. Ok Ill buy that to a certain extent but then why does the ATF want the SN, Manufacturer, and address all to be from the company who made the lower in the case of an AR15? If I am now the manufacturer why isn't my information input into those sections of the form 1?

    In addition, for those that have filled out a form 1 and actually paid attention to the 3rd and 4th pages of the form, it explicitly explains each and every square, even goes so far as to tell you what color of ink to fill the paper out with but yet nowhere on the form does it say a word about engraving. Furthermore, for years people were able to fill out the form 1 with multi as caliber, or list multiple calibers yet everyone who Ive seen with an engraved lower only lists the persons name or trust name and the city/state. Now it seems the ATF will no longer allow mult as an answer to caliber even though its still in the drop down tab on the eform 1 as a caliber and will not allow multiple calibers at least on the eforms.

    Next PWS and Noveske's factory SBR lowers are marked multi or don't even list a caliber so are they violating ATF rules? If you go by the letter of the law from what is shown on the ATFs website for what some say is the requirements for an individual as well since they are now a manufacturer when they slap a short barrel on, they would have to have an actual caliber engraved as well as their name and location.

    It just makes no sense to me how we as individuals are required to engrave lowers that we have done nothing but put a short barrel on the upper, when everything I read points to it not being necessary. Maybe just my wishful interpretation of what Im reading? Ive even seen copies of letters from the ATF posted on various forums saying engraving is not necessary but have also seen some that say it is. Ive also read forum posts from people saying they talked to such and such with the ATF and they were told they needed to but I think we can all agree that you can ask the same question to 10 different people there and get 10 different answers with how terribly unorganized they are. FWIW Ive also read a few forum posts saying they talked to some at the ATF and they were told they didn't need to. Thus my retreat to trying to find it laid out on a .gov site.

    I would just email the ATF to get an answer for myself but Im afraid of opening up a can of worms if in fact what some of these manufacturers have been doing is not right. Ive read through the ATF's site pretty thoroughly and am mainly wondering if Ive overlooked something on their site. Forum posts from joe blow aren't enough for me, Im looking for actual information from a legit website. To me it seems at the very least, people who are not getting the caliber engraved as well are not following the letter of the law when theyre using a lower that is marked multi by the original manufacturer. Also with there seeming to be a shift in what the ATF is allowing for caliber entries on the forms, if you did engrave your lower with 5.56 but then ran a 300blk barrel you could send a letter to the ATF noting your caliber change but your lower would be out of compliance with the rules since its not engraved with the correct caliber. In this thread there are multiple people who were disapproved due to putting multi in the caliber box
    My efiled form 1 was approved in 3 months - AR15.COM

    I know the simple answer is just get it engraved and call it good but Ive never been one to just go with the flow. I like to know why Im doing something and what is actually right but like with anything else the government has something to do with its a very convoluted journey to get to answer that may or may not be definitive.
     

    Renegade

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    Mar 5, 2008
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    Texas
    For the sake of discussion I know there have been many posts on this subject all over the internet Id like some information from a directly citeable(is that a word?) where for an individual filing a form 1 is required to engrave the firearm. As Ive started to receive my form 1s back Ive been doing a ton of reading on this subject because there is very little information on it pertaining to an individual registering their firearm as a SB whatever.

    To pretext this Im not saying Im right, just simply trying to find someone that can show me where on the ATF site that engraving is required by an individual registering a firearm as a short barrel.


    § 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 1/16inch; 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:

    ...

    An 07 FFL is a "manufacturer", a 10 FFL is an "importer", an unlicensed individual is a "maker".
    Some will say that by filing the form 1 YOU are now the manufacturer. Ok Ill buy that to a certain extent but then why does the ATF want the SN, Manufacturer, and address all to be from the company who made the lower in the case of an AR15? If I am now the manufacturer why isn't my information input into those sections of the form 1?

    They want both. If their is existing info, they want that. If not skip it. They then have you the maker and the original maker.

    In addition, for those that have filled out a form 1 and actually paid attention to the 3rd and 4th pages of the form, it explicitly explains each and every square, even goes so far as to tell you what color of ink to fill the paper out with but yet nowhere on the form does it say a word about engraving. Furthermore, for years people were able to fill out the form 1 with multi as caliber, or list multiple calibers yet everyone who Ive seen with an engraved lower only lists the persons name or trust name and the city/state. Now it seems the ATF will no longer allow mult as an answer to caliber even though its still in the drop down tab on the eform 1 as a caliber and will not allow multiple calibers at least on the eforms.

    Multi has never been valid even though some were able to slip it through.

    Next PWS and Noveske's factory SBR lowers are marked multi or don't even list a caliber so are they violating ATF rules? If you go by the letter of the law from what is shown on the ATFs website for what some say is the requirements for an individual as well since they are now a manufacturer when they slap a short barrel on, they would have to have an actual caliber engraved as well as their name and location.

    There is no requirement to even mark the lower with a caliber. They could put "Plasma Rifle in the 40 watt range" and it would be legal. They put the caliber on the BBL to meet legal requirements.

    I know the simple answer is just get it engraved and call it good but Ive never been one to just go with the flow. I like to know why Im doing something and what is actually right but like with anything else the government has something to do with its a very convoluted journey to get to answer that may or may not be definitive.

    The CFR posted above makes it about as simple as it can get.

    " You, as a manufacturer, importer, or maker of a firearm, must legibly identify the firearm"
     

    1slow01Z71

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    Jun 24, 2012
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    Kyle
    So youre saying as long as the barrel is stamped with the caliber and your lower has name/trust with location youre OK? Have you done any eform 1s? Seems odd to me that since the ATF doesn't accept multi anymore that its an option on their site. Since they don't allow selecting multiple calibers on the eform to be legit it sounds like you would have to send em a letter stating the caliber change and the barrel stamp would satisfy the engraving portion for caliber correct? Im going to be run a couple different combinations on a couple of my SBR lowers and with the ATF no longer allowing eform 1 submissions with multiple calibers listed it makes it a bit confusing compared to the old way of submitting a paper form with the calibers you intend to use on that lower.

    Some say you have to be able to return it to the original configuration on your form 1, do you know if that's true? Technically my 300blk is registered with an 8.2" barrel but I couldn't find a noveske so I went with a 9" AAC and same for my 5.56 lower, the barrel is an inch shorter than what is on my form 1.
     

    Renegade

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    So youre saying as long as the barrel is stamped with the caliber and your lower has name/trust with location youre OK?

    Yes. You can also put the name/state on the BBL. This is common on guns where BBLs are cheap an not likely to be swapped, like an Uzi. Put info on BBL, do not mark reciever thus protecting its collector value.

    Have you done any eform 1s?

    No, I am FFL.

    Seems odd to me that since the ATF doesn't accept multi anymore that its an option on their site. Since they don't allow selecting multiple calibers on the eform to be legit it sounds like you would have to send em a letter stating the caliber change and the barrel stamp would satisfy the engraving portion for caliber correct?

    There is no requirement to notify them of any changes.


    Some say you have to be able to return it to the original configuration on your form 1, do you know if that's true?

    There is no legal requirement for this.

    Technically my 300blk is registered with an 8.2" barrel but I couldn't find a noveske so I went with a 9" AAC and same for my 5.56 lower, the barrel is an inch shorter than what is on my form 1.

    Non issue.
     

    Flight954

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    Apr 21, 2008
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    Cypress, TX
    I'm just as curious about this as you are and have also done some reading on this subject and it all still seems somewhat fuzzy. I have multiple SBR's (POF, Rock River and Nodak Spud) engraved with my info even though I was not the actual manufacturer. The only reason I had my info engraved on the lowers is because everyone else in the NFA ownership club has done it.
    Sean Cody would be the guy to weigh in on this.

    This is off of Guntrustlawyer.com
    ATF 5300.4
    in 27 CFR 479.102 (page 92) describes what is necessary to engrave on a SBR or SBS when one is manufacturing. This is not necessary if you purchase one that is already manufactured as it will have been done for you.

    1) On the Frame or Receiver the Serial number;
    2) on the frame, receiver, or barrel the following additional information;
    A)The model;
    B)The caliber or gage;
    C)Your name or name of the Trust in the case of a Trust (no abbreviations are permitted for the Trust name);
    D)The city and state (you can abbreviate the state with the official 2 digit state code)​
     

    1slow01Z71

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    Jun 24, 2012
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    Kyle
    Yes. You can also put the name/state on the BBL. This is common on guns where BBLs are cheap an not likely to be swapped, like an Uzi. Put info on BBL, do not mark reciever thus protecting its collector value.



    No, I am FFL.



    There is no requirement to notify them of any changes.




    There is no legal requirement for this.



    Non issue.
    I know youre a SOT but was wondering if you had done any for your personal stash or help friends with the eform system to see what I was talking about. The notifying the ATF is born out of reading some forum posts and not being able to find it on the ATF's site, thus the questions about changing.

    Thanks for the answers. Figured I was overlooking something on their site. Just got frustrated reading through all the BS on various forums and wading through the ATF's site is painful with all the legal speak.
     

    IXLR8

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    If I understand correctly the engraving must be visible without removing any parts. Is this correct?
    I have an MP5 clone SBR, but want to add a rail on top. By doing so it will hide the serial number. The rail can be removed with an allen wrench. Can someone confirm if this is acceptable?
     

    Renegade

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    Thanks for the answers. Figured I was overlooking something on their site. Just got frustrated reading through all the BS on various forums and wading through the ATF's site is painful with all the legal speak.

    I understand. Before I had FFL I did some Form 1s, it was very confusing. Everyone had an opinion. I stopped listening and decided to read US Code & CFR and know it by heart.
     

    Renegade

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    If I understand correctly the engraving must be visible without removing any parts. Is this correct?
    I have an MP5 clone SBR, but want to add a rail on top. By doing so it will hide the serial number. The rail can be removed with an allen wrench. Can someone confirm if this is acceptable?


    The inconspicuous part applies to the person who made it, not the end user. So when it left HK it had to be visible. You as end user can put a rail on top no problem.
     

    Reaper277

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    I've been wondering about all this too, I'm getting ready to do my first form1 and all the different "must do" I've read are confusing.
    So if I have to engrave my city and state on my lower, it's still good to go when I move to another city bc it's engraved with the city where the trust was created? Is this correct?
     

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