Engraving a Form 1 SBR

[wack86]

Is there a definitive answer to what must be engraved on your SBR after Form 1 approval? I have gotten many different responses:

1. My local Class 3 dealer told me nothing needs to be engraved.
2. I called an out-of-state dealer and they told me that I need to engrave my Name and City on the lower.
3. I called the NFA office this morning and they told me all I need to do is engrave the serial number of the receiver on each barrel that will be used with the lower. I asked him for some documentation he could refer me to and he said that there was none.

Does somebody out there in AR Land have some authoritative documentation from the BATF outlining what needs to be specifically engraved?

[r2kba]

Originally posted by wack86
Is there a definitive answer to what must be engraved on your SBR after Form 1 approval? I have gotten many different responses:

1. My local Class 3 dealer told me nothing needs to be engraved.
2. I called an out-of-state dealer and they told me that I need to engrave my Name and City on the lower.
3. I called the NFA office this morning and they told me all I need to do is engrave the serial number of the receiver on each barrel that will be used with the lower. I asked him for some documentation he could refer me to and he said that there was none.

Does somebody out there in AR Land have some authoritative documentation from the BATF outlining what needs to be specifically engraved?

NAME, CITY, STATE is what I've been read. But I'm surprized that they told you that on the phone! I guess take your pick. I seriously doubt that as long as you did ONE of those two things ( Your class 3 Dealer is on crack ) the ATF would care one way or another.

[HotGuns]

Name,City,State and serial number that you give it. It must be a least 3/32 tall and be at least .005 deep.

There is some documentation on it, in the form of case letters and decisons but I cannot for the life of me find it.

decison letter ATF (http://www.cs.cmu.edu/afs/cs/user/wbardwel/public/nfalist/atf_marking_reg.txt)

last paragraph...



Sec. 179.102 How must firearms be identified?

PART 179--MACHINE GUNS, DESTRUCTIVE DEVICES, AND CERTAIN OTHER
FIREARMS

Par. 3. The authority citation for 27 CFR part 179 continues to
read as follows:

Authority: 26 U.S.C. 7805.

Par. 4. Section 179.102 is revised to read as follows:


Sec. 179.102 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

[[Page 33453]]

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 on and after [insert effective date of final
rule], the engraving, casting, or stamping (impressing) of the serial
number must be to a minimum depth of .005 inch and in a print size no
smaller than 3/32 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 on and after [Insert effective date
of final rule], the engraving , casting, or stamping (impressing) of
this information must be to a minimum depth of .005 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; and
(v) In the case of an imported firearm, the name of the country in
which it was manufactured and the city and State (or recognized
abbreviation thereof) where you as the importer maintain your place of
business.
(b) The Director may authorize other means of identification upon
receipt of a letter application from you, submitted in duplicate,
showing that such other identification is reasonable and will not
hinder the effective administration of this part.
(c) In the case of a destructive device, the Director may authorize
other means of identifying that weapon upon receipt of a letter
application you, submitted in duplicate, showing that engraving,
casting, or stamping (impressing) such a weapon would be dangerous or
impracticable.
(d) A firearm frame or receiver that is not a component part of a
complete weapon at the time it is sold, shipped, or otherwise disposed
of by you must be identified as required by this section.
(e)(1) Any part defined as a machine gun, muffler, or silencer for
the purposes of this part that is not a component part of a complete
firearm at the time it is sold, shipped, or otherwise disposed of by
you must be identified as required by this section.
(2) The Director may authorize other means of identification of
parts defined as machine guns other than frames or receivers and parts
defined as mufflers or silencers upon receipt of a letter application
from you, submitted in duplicate, showing that such other
identification is reasonable and will not hinder the effective
administration of this part.

Signed: April 12, 1999.
John W. Magaw,
Director.

Approved: June 4, 1999.
Dennis M. O'Connell,
Acting Deputy Assistant Secretary, (Regulatory, Tariff and Trade
Enforcement).
[FR Doc. 99-15943 Filed 6-22-99; 8:45 am]
BILLING CODE 4810-31-P

[kengps]

I did a SB shotgun. As far as I know as long as you are modifying an existing gun you just list the serial number of the original manufacturer. The receiver then becomes a title 2 firearm. Even with a standard barrel it will always be a title 2 receiver. The barrel doesn't need anything engraved on it.

[r2kba]

Originally posted by kengps
I did a SB shotgun. As far as I know as long as you are modifying an existing gun you just list the serial number of the original manufacturer. The receiver then becomes a title 2 firearm. Even with a standard barrel it will always be a title 2 receiver. The barrel doesn't need anything engraved on it.


This has been heavily debated by people with much more qualifications than us. The consensus is You DO need to place your name city and state on the receiver, _OR_ barrel in a conspicuous place.

Since ATF wont make it clear, you are better off airing on the side of caution. I Scribbled my name city and state on my last SBR with a hand held engraver. Took 2 minutes.

[pnhurst]

Name, City, State. No S/N unless building from scratch.

1/16 inch height, .003 deep.

http://www.atf.gov/regulations/td461.pdf (yes, 1 1/16 inch height is a typo).

[Brooklyn South]

I'd never read anything before about a requirement to engrave the barrel or uppers.

Good shooting!
:) :) :) :)

[kengps]

Neither have I. The ATF instruction sheet says nothing about it. I think they just want to be able to ID a weapon. If you are modifying an existing weapon already marked then why put your name on it? I can understand if you are making from scratch. All weapons are requred to have the manufacturers name and place of origin. I think maybe some people are confusing these requirments and applying them to class 3 conversions of existing guns.

[r2kba]

Just because ya havent heard of it dosent meant it dosen't need to be done.


FORM-1 = MAKE-AND-REGISTER-FIREARM

[kengps]

Originally posted by r2kba
Just because ya havent heard of it dosent meant it dosen't need to be done.



Just because you haven't heard of it, doesn't mean it needs to be done either.

[Brooklyn South]

Originally posted by r2kba
Just because ya havent heard of it dosent meant it dosen't need to be done.

True. I guess I should have added that I have read many times of the need to engrave the receiver, with no mention of the requirement to engrave the barrel or upper receiver.

Good shooting!
:) :) :) :)

[wack86]

Thanks for the help guys. One last question: Can you use abbreviations, or do the Name, City and State need to be spelled out completely? My Form 1 is done on a trust and the name is quite lengthy when you consider having to engrave it.

[r2kba]

Originally posted by wack86
Thanks for the help guys. One last question: Can you use abbreviations, or do the Name, City and State need to be spelled out completely? My Form 1 is done on a trust and the name is quite lengthy when you consider having to engrave it.

The full trust name would need to be engraved. Either on the barrel, or receiver.

[bunky]

Originally posted by pnhurst
Name, City, State. No S/N unless building from scratch.

1/16 inch height, .003 deep.

http://www.atf.gov/regulations/td461.pdf (yes, 1 1/16 inch height is a typo).

+1

I registered a SBR Colt AR15 a year or so ago. I had the engraving done to the front of the magwell. The guy that did it was advertising on AR15.com and did a magnificent job. I've met a lot of people who did not realize the engraving had to be done - some of whom had already registered their guns and placed the short barrels on them.

Just go to the BATF website and email them directly, and you'll get a response confirming this. Believe me, I kinda hated to engrave my name on my rec'r since I sure as hell can't sell it down the road now if need be.

[bunky]

Originally posted by r2kba
The full trust name would need to be engraved. Either on the barrel, or receiver.

The BATF informed me that the engraving had to be done on the receiver - nothing else. Maybe I'm misreading your post....

[r2kba]

Originally posted by bunky
The BATF informed me that the engraving had to be done on the receiver - nothing else. Maybe I'm misreading your post....


PART 179—MACHINE GUNS,
DESTRUCTIVE DEVICES, AND
CERTAIN OTHER FIREARMS


Par. 3. The authority citation for 27
CFR Part 179 continues to read as
follows:
Authority: 26 U.S.C. 7805.
Par. 4. Section 179.102 is revised to
read as follows:
§ 179.102 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; and
(v) In the case of an imported firearm,
the name of the country in which it was
manufactured and the city and State (or
recognized abbreviation thereof) where
you as the importer maintain your place
of business. For additional requirements
relating to imported firearms, see
Customs regulations at 19 CFR part 134.
(b) The depth of all markings required
by this section will be measured from
the flat surface of the metal and not the
peaks or ridges. The height of serial
numbers required by paragraph (a)(1) of
this section will be measured as the
distance between the latitudinal ends of
the character impression bottoms
(bases).
(c) The Director may authorize other
means of identification upon receipt of
a letter application from you, submitted
in duplicate, showing that such other
identification is reasonable and will not
hinder the effective administration of
this part.
(d) In the case of a destructive device,
the Director may authorize other means
of identifying that weapon upon receipt
of a letter application from you,
submitted in duplicate, showing that
engraving, casting, or stamping
(impressing) such a weapon would be
dangerous or impracticable.
(e) A firearm frame or receiver that is
not a component part of a complete
weapon at the time it is sold, shipped,
or otherwise disposed of by you must be
identified as required by this section.
(f)(1) Any part defined as a machine
gun, muffler, or silencer for the
purposes of this part that is not a
component part of a complete firearm at
the time it is sold, shipped, or otherwise
disposed of by you must be identified as
required by this section.
(2) The Director may authorize other
means of identification of parts defined
as machine guns other than frames or
receivers and parts defined as mufflers
or silencers upon receipt of a letter
application from you, submitted in
duplicate, showing that such other
identification is reasonable and will not
hinder the effective administration of
this part.

[bunky]

I spoke to BATF Officials on the phone and via several emails. Being that an AR15 barrel can be readily removed and replaced, I was instructed to engrave the rec'r. This topic is covered on AR15.com extensively. It doesn't make sense to engrave the barrel when the receiver is the "firearm" itself, not the barrel. Incidentally, BATF would not allow the engraving to be done underneath the pistol grip where it could not be seen.

However, BATF "rulings" change all the time. Who can keep up with it all?

[r2kba]

Originally posted by bunky
I spoke to BATF Officials on the phone and via several emails. Being that an AR15 barrel can be readily removed and replaced, I was instructed to engrave the rec'r. This topic is covered on AR15.com extensively. It doesn't make sense to engrave the barrel when the receiver is the "firearm" itself, not the barrel. Incidentally, BATF would not allow the engraving to be done underneath the pistol grip where it could not be seen.

However, BATF "rulings" change all the time. Who can keep up with it all?


I never said to conceal it, but the regulations clearly say marking the barrel is ok, on their own website.

Just because someone tells you something on the phone, dosent mean it's accurate. Tell him to put that in WRITING and mail it to you signed by an ATF Official, and see what they say THEN. A defense to prosecution is not " your atf employee told me it was ok on the phone".

Section 1 deals with the _SERIAL NUMBER_ of a firearm, which must be on the frame or receiver.

Subsequent identifying information, Section 2, can be placed on the barrel, and it is acceptable. All you have to do is look at any Remington arms MFG rifle and you will see this information on the barrel.

This is my understanding of this process explained by SOT's and knowledgeable individuals. Form1's do not alter the serial number of the firearm, a Form1 uses the original serial number and you are not permitted to change it since obliterating the serial number of a firearm is against state AND federal law. SOTs may be able to do this, however since I'm not an SOT I don't know that part.

[bunky]

If I'd known I could have marked only the barrel, that's what I would have done. I registered mine as "multiple barrel length" since I have 11.5" and 14.5" barrels.

I searched their site back when I did mine and I didn't find that info. Several emails w/BATF Officials indicated the necessity of engraving first/last name and city/state on the rec'r. I was informed that marking the barrel(s) (as well as underneath the pistol grip) was unacceptable. I, for the life of me, don't know why they'd intentially misinform me, but it's no big deal as it's already done. I have the engraving professionally done to the front of the magwell, and it looks very nice. At least it's not easily seen. Thanks for the info and Merry Christmas.

[r2kba]

Originally posted by bunky
If I'd known I could have marked only the barrel, that's what I would have done. I registered mine as "multiple barrel length" since I have 11.5" and 14.5" barrels.

I searched their site back when I did mine and I didn't find that info. Several emails w/BATF Officials indicated the necessity of engraving first/last name and city/state on the rec'r. I was informed that marking the barrel(s) (as well as underneath the pistol grip) was unacceptable. I, for the life of me, don't know why they'd intentially misinform me, but it's no big deal as it's already done. I have the engraving professionally done to the front of the magwell, and it looks very nice. At least it's not easily seen. Thanks for the info and Merry Christmas.


ATFE changes yearly. NOW, there may be an SOT that says " nah R2KBA, you have to engrave the bbl on a form1 " and thats fine. But so far, I've not found this to be the case. If ATFE wants to go by the barrel being readily removable, then they need to specify. With an AR15, you really dont have any CHOICE but to engrave the reciever because the BBL is not exposed. Besides, a good pro engrave job looks GREAT.

The gun I marked the BBL on is my 870. YEAH the barrel can be removed, but sowhat. The serial number on the receiver is registered under NFA as a SBS. When remington MFG the gun, they put their name city and state on the barrel, so theres no reason I can't do the same thing when I REGISTER it as a SBS.

My 10/22 however is engraved on the receiver, due to the bbl being covered up by a krinker plinker kit.

[bunky]

My next short-barreled weapon will be a SBS. I'd gladly give up the capacity extension for the shorter, 14" or so, barrel length. Very handy weapon when exiting a police cruiser in a hurry.

[r2kba]

Originally posted by bunky
My next short-barreled weapon will be a SBS. I'd gladly give up the capacity extension for the shorter, 14" or so, barrel length. Very handy weapon when exiting a police cruiser in a hurry.


Yeah mine is 14" but I can't use it on duty. I dont have the rear ghostring mounted yet. Just another thing I dont have cash or time for right now :)

[psychoshot]

Guys, on an AR SBR made on a from 1 you should use some common sense and have the receiver engraved. Once you SBR that receiver, it is a title 2 firearm no matter if it has a 24" barrel or a 5" barrel.

If you engrave the barrel, you would have to engrave every AR barrel you plan to use because if you don't, technically you would have an unmarked SBR if you are using an upper that is does not have the name and city/state of the maker.

If your trust is the maker, you don't have to spell out the complete name. J.B. Smith Trust is sufficient to identify the maker. The actual rule says:

Linky (http://www.atf.gov/pub/qtrly_bulletins/vol3_qb2001/subpartc.pdf)

§ 179.102 How must firearms be identified?
(2)(iii) Your name (or recognized abbreviation)......

No need for John Brian Smith Revocable Living Trust to be engraved. Ever seen a a receiver like one from Patriot Ordnance Factory Inc. It is marked POF-USA

The engraving has to be someplace conspicuous which most interpret right or wrong is someplace that it can be seen without disaaembly of the firearm in whole or partially.

So most people do under the trigger guard, front of magwell or right side of magwell. You can see examples of all of those here.

Orion Arms (http://www.orion-arms.com/AR15.php)

None of the above is legal advice. IANAL

Oh, one more thing. The smart thing to do is send your receiver off to have it engraved and once you have it back in your hands, send your form 1 in to the ATF. You can engrave anything you want on a title 1 firearm. If you wait until you get your approved form 1 back, now you are shipping a title 2 firearm around which you paid a $200 tax on. What if it gets lost? What if the engraver screws up? Damages the receiver somehow?

[r2kba]

Nobody is suggesting to engrave the barrel of an AR, which you can't see in most cases.

[psychoshot]

Originally posted by r2kba
Nobody is suggesting to engrave the barrel of an AR, which you can't see in most cases.

Well actually they are:

Originally posted by bunky
If I'd known I could have marked only the barrel, that's what I would have done. I registered mine as "multiple barrel length" since I have 11.5" and 14.5" barrels.


Originally posted by r2kba

The full trust name would need to be engraved. Either on the barrel, or receiver.

But I don't want to argue the point.

[r2kba]

Originally posted by psychoshot
Well actually they are:




But I don't want to argue the point.


Yeah but the point is, it's legal to do so. I however said on an AR, to mark the lower, not the BBL. On a shotgun, however, mark the bbl, or receiver, It matters not.

[psychoshot]

That's true and I never said it wasn't legal. I said use some common sense. Legally you can engrave an AR barrel, however, if you change to an upper that is not engraved, no matter what the length then you will have an unmarked SBR. Which is why if you ask ATF they will tell you mark the receiver. They won't tell you engraving the a barrel on a AR is illegal because it is modular.

Now, who is going around checking and would it ever be questioned at a range? Probably not but people should be aware if they choose to engrave the barrel. OK?
:thumbsup:

[Glockdude1]

Originally posted by kengps
I did a SB shotgun. As far as I know as long as you are modifying an existing gun you just list the serial number of the original manufacturer. The receiver then becomes a title 2 firearm. Even with a standard barrel it will always be a title 2 receiver. The barrel doesn't need anything engraved on it.

:thumbsup: That is exactly right.

The only time you would have to put you name, address & serial number on a barrel is if you CREATED the entire weapon. By just adding a short barrel (example: Uzi), nothing needs to be done to the barrel.