NFA engraving?

"This is different than some of the opinions I've seen shared on SilencerTalk."


Well.... folks can print all the opinions they like. I got the informal opinion of my local BATFE ofice when I was discussing another subject., and it's that *they* don't care, but that's their local opinion and is not a formal one. If you want a letter, send a request for a determination to the BATFE tech guys and you'll get whatever answer they decide to give. I'm happy with the answer I got, and figure that if someone else disagrees I'll ask forgiveness. Not worth worrying about, but feel free to feel otherwise. Everyone has their own comfort level for this stuff.


Willie

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Elkins45 said:

This is different than some of the opinions I've seen shared on SilencerTalk. One of the reasons I went with 10" rather than 7" was because of the extra 3" past the gas block to engrave on. I wonder if there's an "official" letter out there somewhere?

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There is a recent paranoia about covering that completely ignores a long history of aftermarket revolver grips (and even some factory S&W grips) that cover the serial number, scope rings over Mauser markings, shotgun serial numbers on the water table, etc., etc., etc.

Mike

Arizona_Mike said:

There is a recent paranoia about covering that completely ignores a long history of aftermarket revolver grips (and even some factory S&W grips) that cover the serial number, scope rings over Mauser markings, shotgun serial numbers on the water table, etc., etc., etc.

Mike

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Yeah, but don't the NFA regs specifically say "wholly unobstructed from plain view" or words to that effect? Seems like I saw that language somewhere.

Elkins45 said:

Yeah, but don't the NFA regs specifically say "wholly unobstructed from plain view" or words to that effect? Seems like I saw that language somewhere.

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The restrictions in the NFA, CGA, and CFR, and NFA handbook are "removed, obliterated, or altered"

There is a 2002 ruling by the ATF that contradicts historical practice but appears to only apply to the first time the firearm is made, nothing stops you from changing handguards later.

Mike

While other weapons are mentioned in the ruling, the only two holdings (IE: formal opinions in the ruling cited) regard importers serial number markings. In fact the entire ruling has to do wioth serial number, not other markings. Legally it has nothing to do with where we mark the other information on what we build with Form 1's. Note than none of this is carved in stone.

My vibro-engraver has always suited my needs.


Willie

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bikemutt said:

For folks in the Western WA area, Trevor with Jet-City Laser in Auburn does excellent laser engraving after 4:15 pm. He may be reached at 253-293-2164. It took less than 30 minutes to engrave the trust and city/state on this aluminum receiver. Any blurring seen in the photo is the result of camera focus, the engraving is crisp and legible in reality.

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Thanks for the bump man, I really appreciate it.

Trevor K.
253-293-2164

Elkins45 said:

If you "make" a short barreled rifle or shotgun from an existing firearm you are required to engrave additional information on the gun. Specifically you must add the name, city and state of the person who turned it into an NFA item.

If you are making a silencer then you must also add the caliber and a serial number. A preexisting firearm already has that stuff engraved so you don't need to add it.

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To add to that, if your rifle is a NFA Trust firearm, it must also be engraved with the trust ownership.

www.caddgraphics.com is in Murphy, NC, for anyone in the central Southeast who needs firearms engraving. Good work, good pricing, and generally fast turnaround times.

"To add to that, if your rifle is a NFA Trust firearm, it must also be engraved with the trust ownership".

Well.... kind of. But not "also". The correct thing would be "instead of". When a trust "makes" a NFA item, the *trust* name is engraved. The Trustee (you) don't get your name engraved anyplace. Just keeps it easy.


One trick for AR based SBR's is to realize that you do not need to engrave the lower.

You can engrave the UPPER or the BARREL on the upper.

Why?

Well......

(A): When it's not installed the lower isn't a NFA item... thus no markings are needed.

(B): When the upper is installed the rifles then becomes a NFA item and requires the markings.

Sort of a self-fulfilling thing, so to speak. As long as the lower is what is on the paperwork, you can take it into and out of NFA configuration by exchanging uppers. If each SBR upper you install has it's own engraving, you are good to go. Vibro-engave the barrel and have at it. Vibro-engrave the barrel and enjoy.


Why do this? Well... If you're using a nice collectable old Colt SP-1 lower you might not want to ruin it's value by engraving. Put its original upper assembly in the safe, snap on a properly marked SBR upper, and enjoy. This allows you to have your cake and eat it too.


Willie

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Why do this? Well... If you're using a nice collectable old Colt SP-1 lower you might not want to ruin it's value by engraving. Put its original upper assembly in the safe, snap on a properly marked SBR upper, and enjoy. This allows you to have your cake and eat it too.

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Conversely, I'd rather electro pencil a $50-$75 run-of-the-mill lower than any part of the uppers I swap onto it.

Willie- I see what you're saying but have another question. When you submit the Form 1, you have to include the serial number for the lower. So even if you engrave the upper, removing it from the lower would still not change the fact that the lower is still a registered NFA item, correct?

Olympus said:

Willie- I see what you're saying but have another question. When you submit the Form 1, you have to include the serial number for the lower. So even if you engrave the upper, removing it from the lower would still not change the fact that the lower is still a registered NFA item, correct?

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That is correct. Read here for details:

https://www.atf.gov/firearms/faq/national-firearms-act-short-barreled-rifles-shotguns.html

Olympus said:

Willie- I see what you're saying but have another question. When you submit the Form 1, you have to include the serial number for the lower. So even if you engrave the upper, removing it from the lower would still not change the fact that the lower is still a registered NFA item, correct?

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Right, but I think Willie's point is that it's not an obviously marked (defaced) lower. You can shoot it in an SBR configuration with a properly engraved upper, but then put it back into pristine-looking SP-1 configuration for "everyday" wear. Kind of a "stealth" SBR. Plus, if you ever decide to permanently remove it from the NFA registry (by simply getting rid of the SBR upper and sending in a letter), the lower is still "unblemished" by engraving.

^^ This, precisely.

I vibro-engrave the barrels under the handguard and that's that. Nobody but someone really asking *from a position of authority* (meaninfg essentially the BATFE) needs to see the markings, and as I stated before, a call to my local BATFE office gained me the answer that they really don't care if the handguard needs to be removed to see the markings. YOUR actual mileage may vary, but I am satisfied that I am in compliance by doing this. Let's face it, the BATFE has more important thigns to do than to litigate "where" a Form 1 SBR has it's makers markings engraved *even it it became a controversy* (which I really doubt would ever become the case).


"Willie- I see what you're saying but have another question. When you submit the Form 1, you have to include the serial number for the lower. So even if you engrave the upper, removing it from the lower would still not change the fact that the lower is still a registered NFA item, correct?"


Correct, but think of it this way: The approved Form 1 allows my trust to make a SBR from that now-NFA registered (taxed) lower. I can make it, and I can unmake it. And again make it, and unmake it... ad nauseum. When it's in SBR configuration the makers name needs to be on the rifle as per BATFE marking requirements. When it's not in NFA configuration all I have is a Title 1 firearm (Non-NFA) that has the "potential" to be legally configured as a SBR *but isn't at the moment* and thus no makers markings (for the NFA registered maker) needs to be present. The TITLE 1 makers name (Colt) is on the lower... that takes care of that requirement. Basically I have a rifle with TWO "Makers". That's all OK. And as is pointed out above, one day I can simply remove the short bareled upper, hit the markings on the vibro-engraved BBL with a grinder and sell it, have the lower removed from the NFA, and then put the original upper back on and call it a day without destroying the value of my (collectable) SP-1.


Not to mention the obvious... IF I want nice engravings, I can send the BARREL (or the upper) to any engraver for work as I am not sending a firearm (read that "I do not need to send it to a FFL") as recipient for engraving.


BTW: A great Trust name is "In God We Revocable Trust".

Engraving on my barrels?

"In God We Trust"


Think about that Mr. BATFE looking for my engraved name......


Willie

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Conversely, I'd rather electro pencil a $50-$75 run-of-the-mill lower than any part of the uppers I swap onto it.

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Exactly!

Unless they close the registry to SBRs, registering a lower doesn't add any value, so why spend a significant sum on engraving? Deface the lest expensive part to replace, even a "brand name" stripped lower sill cost less than a decent barrel.

My vibro-engraver has always suited my needs.

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And I thought I was the only one.

"Conversely, I'd rather electro pencil a $50-$75 run-of-the-mill lower "

Some don't use "run of the mill" lowers.


even a "brand name" stripped lower sill cost less than a decent barrel.


Ok.

I'll take all the Colt SP-1 lowers you can send me if you can find them for less than the cost of a blaster-quality SBR barrel....


Willie

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Thanks for the clarification. I understand now!

You can engrave the UPPER or the BARREL on the upper.

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Unless I misunderstand, the letter of the law doesn't allow for the upper to be engraved. It specifically lists the barrel. I wish it was the upper--much easier than the barrel for the home engraver.

I believe you are incorrect. Read 6.2.1 of https://www.atf.gov/files/publications/download/p/atf-p-5320-8/atf-p-5320-8-chapter-6.pdf and 7.4.2 of https://www.atf.gov/files/publications/download/p/atf-p-5320-8/atf-p-5320-8-chapter-7.pdf

"Unless I misunderstand, the letter of the law doesn't allow for the upper to be engraved. It specifically lists the barrel. I wish it was the upper--much easier than the barrel for the home engraver"


The guidance (which is what it is, not a regulation) states "Barrel, Frame, or Receiver". But that's not all-inclusive. Witness every semi auto pistol you've ever held... marked with the additional infomation on the slide.


Willie

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