Question regarding engraving requirements.

[Acera]

Ok, heard a different story from a gun store employee yesterday regarding engraving on a SBS.

I was under the assumption that the engraving requirement for the makers name and location (trust name, city & state for my build) had to be visible.
The serial number, original makers name, etc. is unchanged and on the receiver where they are easily seen.

I am waiting on approval for a SBS, I plan on having the engraving on the barrels. Had planned on putting it just above the top edge of the forestock, just under where the rib is attached. Completely visible when the gun is fully assembled.

Was told that it could be put under forestock. In that case, looking at the fully assembled SBS shotgun you would not see the engraving unless you took the forestock off.

Anybody know if this is correct?

 

[yugorpk]

It has to be visble and not covered by the forend.

 

[Acera]

Thanks yugorpk,

Do you have a link where I can reference that?

I would like to be able to print that out and take it in with me next time I visit their shop.

 

[Swing]

Here you go:

7.4.2 Additional information. Certain additional information must also be conspicuously placed on
the frame, receiver, or barrel of the firearm by engraving, casting, stamping (impressing), that is, they
must be placed in such a manner that they are wholly unobstructed from plain view. For firearms
manufactured on or after January 30, 2002, this information must be to a minimum depth of .003 inch.
The additional information includes:

(1) The model, if such designation has been made;
(2) The caliber or gauge;
(3) The manufacturer’s name (or recognized abbreviation); and
(4) The city and State (or recognized abbreviation) where the manufacturer maintains its place
of business.122

 

[pjeski]

Swing,
That quote is from the NFA handbook, which is not law. While it is published by the ATF, it is written by NFATCA.

 

[Ryanxia]

We had a long discussion about this recently. It was my opinion that in the case of a free float rail, it could be covering the engraving, but my thought with that is that you can still see the engraving through the holes in most free float rails. Others thought it was quite clear that it would not be acceptable.

I think you'll get some different answers but my opinion is that it would be worth just engraving somewhere outside of the foreend needing to be removed. Remember you can make it quite small, see the Sticky in this forum for FAQ's including engraving requirements.

TLDR: Aside from the link above my post, there wasn't anything official that came up.

 

[pjeski]

Here are some links to actual law:

26 U.S. Code § 5842 - Identification of firearms
https://www.law.cornell.edu/uscode/text/26/5842

27 CFR 478.92 - How must licensed manufacturers and licensed importers identify firearms, armor piercing ammunition, and large capacity ammunition feeding devices?
https://www.law.cornell.edu/cfr/text/27/478.92

27 CFR 479.102 - How must firearms be identified? (This applies to us with our Form 1s)
https://www.law.cornell.edu/cfr/text/27/479.102

18 U.S. Code § 922 - Unlawful acts
https://www.law.cornell.edu/uscode/text/18/922
(see k)

27 CFR 478.34 - Removed, obliterated, or altered serial number.
https://www.law.cornell.edu/cfr/text/27/478.34

ETA: Here's something I found on the Nebraksa Federal Public Defender's website:
http://ne.fd.org/publications/firearms_cheatsheet.pdf

 

[Acera]

Swing,
That quote is from the NFA handbook, which is not law. While it is published by the ATF, it is written by NFATCA.

Ok, a bit more confused as nothing seems to be clear on this. This may be a grey area that has not been completely clarified by the BATFE.

I would really like to be able to place it on the barrels under the forestock, for looks and having a much larger area to work with.

The length I have applied for does not allow for much barrel exposure in front of the forestock, so a ring of lettering there would not work.

I am even considering putting it directly on the vent rib, and then putting a piece of tape over it at the range. But that would require deeper engraving to get past the checkering already there and compromise the look.

Does it matter that the gun is functional without the forestock? It can be safely fired, (however the barrels will come off when you break it open to reload). The forsetock is an easily removable no tools required piece, does that matter? Trying to think of a popular firearm where some part of the gun or it's accoutrements cover a part of the required lettering as an example.

Thanks all for the continued help.




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[Ryanxia]

I used AR's as an example where the receiver is marked multi but the barrel is marked with the caliber but has a rail covering it. I think some of the bullpups cover the markings too but not 100% sure.

 

[yugorpk]

Theres a reason why you cant think of a single gun where the legally required information is covered even by something that is readily removable.

You could always write the ATF a letter to the tech branch so they can write you your very own opinion letter telling you exactly what we've been telling you here. It needs to be unobstructed and visible. No hand guards in the way etc.

Just do what the rest of us do. As small as legally allowed lettering in a inconspicuous place. With an AR at the lip of the mag well works fine or in the trigger recess area. Blackened and you cant see it unless its pointed out but its still legal. Every gun has some spot like that.

 

[pjeski]

There are many aftermarket grips that cover serial numbers on hand guns. I understand some factory S&W guns even have grips covering the SN.

The AR magwell grip adapters that ATF says are OK on pistols (ie not VFGs) cover most of the factory markings on some guns, including the serial numbers. Not illegal.

There are so many examples of things that cover up markings that are not illegal, as long as you do not remove, obliterate, or alter the markings that were properly made (conspicuously) when the weapon was made or mfg'd.

 

[yugorpk]

While we can disagree on what the law allows and what the ATF would say if asked I think we can all agree that no one actually cares and it would never be an issue no matter what an opinion letter said.

 

[Acera]

There are many aftermarket grips that cover serial numbers on hand guns. I understand some factory S&W guns even have grips covering the SN.

The AR magwell grip adapters that ATF says are OK on pistols (ie not VFGs) cover most of the factory markings on some guns, including the serial numbers. Not illegal.

There are so many examples of things that cover up markings that are not illegal, as long as you do not remove, obliterate, or alter the markings that were properly made (conspicuously) when the weapon was made or mfg'd.

Kinda along the lines of what I was thinking. Even thought about those slip on covers that used to be popular before camo dipping. Lot of sight mounts on semi-auto pistols cover a lot of real estate.

While we can disagree on what the law allows and what the ATF would say if asked I think we can all agree that no one actually cares and it would never be an issue no matter what an opinion letter said.

I can see your point. Unfortunately there is no good place on the receiver to place it's pretty much fully factory engraved. Also, I may want to sell the bare receiver at some point and would not want my trust name, etc. on that. Those two considerations are why I am going with the barrels as my location. No one is going to want a hacked up set of 20 gauge barrels without the rest of the gun, so they may be trashed some day.

Another thing is I can do the engraving myself if I can cover up my non-professional looking script. That would leave the outer appearance pretty good, and provide a amount of protection of who I am, trust name, etc.

I may use that help feature on the ATF efile page and see if I can get an answer from them on it.




All links provided are appreciated as well as the discussion.



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[Arizona_Mike]

Historically revolvers could have numbers under their grips (common for aftermarket grips--was even factory on one S&W model). Other markings often ended up under scope rings, etc.

Until about 2013, I saw a lot of imported break open guns with the serial number on the water table. Right around 2013/2014, I started to see the markings there and the underside of the gun as well (in duplicate). I'm sure they did not start to do something so ugly without being told to by the ATF.

The ATF also required one of the makers of aftermarket AR15 magwell grips at add a "window" before they approved importation but allows other markings to be covered. I'm not rushing to redo any of my revolvers with Uncle Mike's grips or shotguns with my NFA markings on the water table or any of my sporterized Mausers with markings under the scope bases.

Mike

 

[giggitygiggity]

Not trying to hijack the thread, but when you guys engrave NFA info, do you do it yourselves or take it somewhere? If you do it yourself, what do you recommend as the best method? Thanks!

 

[yugorpk]

Ive seen people do it themselves and while its free that way it generally looks horrid which is fine with some people. I use Veritas machine for my engraving needs . They charge around $50 and laser engrave as small as possible and can do it in very inconspicuous places. Every time I get one back from them I am amazed by the work.

 

[pjeski]

You can't go wrong with Veritas. I've also used Ident Marking with good results.

 

[Acera]

Ive seen people do it themselves and while its free that way it generally looks horrid which is fine with some people. I use Veritas machine for my engraving needs . They charge around $50 and laser engrave as small as possible and can do it in very inconspicuous places. Every time I get one back from them I am amazed by the work.

So a laser gets deep enough? I was afraid that it would only break the finish and not get to that magical .003 in depth. I have been searching for a company with one of those old type pantograph engravers that cut into the metal.

If so, this is good news as I got a guy across town that will do my laser engraving for about $40.

Next question yugorpk, regarding the initial conversation about putting the required marking out of plain sight.
I noticed this picture on the Veritas (http://www.veritasmachiningllc.com/#!nfaweapons/c1pl3) webpage, this would seem to counter the argument that it has to be exposed. This marking would be covered when the barrels are installed and closed. However they use it to advertise their services, even stating the compliance thing.




I am not trying to be argumentative, just want to fully understand the issue and do the right thing, while serving my interests as well.


Thanks to all for their continued conversations.


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[pjeski]

They are definitely capable of cutting as deep as you would like.

 

[yugorpk]

Ive been kicking this crap around for 25 years and its always been my understanding that the ATF needs it to be visible from the outside of the gun without having to do anything. I could be wrong but I dont think I am and thats the way I continue to get things engraved. At the same time I recognize the fact that no one actually cares.

Lasers will engrave as deep as you want them to engrave.

 

[Acera]

Ok, well I have an answer from the ATF. I sent them a message late yesterday through their 'Ask The Experts' tab under my account on the eForms site.

Simple, short answer came in an email today.

"The required markings must be conspicuous – see 27 CFR 479.102 for the marking requirements."


I will get it laser engraved, in a place (even where I don't want it to be) where it is conspicuous. A piece of tape should help hide my personal information from curious onlookers at the range.

Thanks for everyone's help.






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[yugorpk]

Remind me not to shoot at your range.

 

[Acera]

Remind me not to shoot at your range.

Yeah, it's a local place where a lot of friendly folks shoot skeet. I have talked to a number of the the range staff about using it on station 1, 7 & 8. They are receptive. Maybe due to years and years of good tipping.

During the middle stations, the gun will be open and laying on top of the gun rack where the rest of the shooters, and new arrivals put their guns. It's a friendly place where it is not unusual for shooters to want to check out what the other shooters have. Of course, they ask before they touch, but a lot get real close to have a look beforehand. I have been able to shoot a wide variety of shotguns either because I liked theirs, or they liked and wanted to shoot mine. First time I shot a Holland and Holland was this way. With what I plan to build, it should get a lot of attention.

How often do you see a Beretta Silver Pigeon O/U 20 gauge that is only 20 inches long with a pistol grip?

In a few months I will probably start a thread on "How do you get burned on tape residue off your shotgun barrel", expecting a lot of WD-40 responses to that one, LOL.

 

[yugorpk]

Just wondering. Why the need to conceal your info ? Ive never heard anyone express that as a need. In any case the engraved information is so small and usually in discreet ( yet conspicuous ) places and blackened so that its hard if not impossible to tell what you have there unless you know what to look for. 1 1/4 inches of info in #4 font on the bottom a barrel is pretty hard to see if its barrel color.

Trust or traditional form 1? If you just want to keep your name off it go trust and use a generic trust name. Mine is (my initials+ trust ) . Good luck tracking me down from that.

 

[Acera]

Just wondering. Why the need to conceal your info ? Ive never heard anyone express that as a need. In any case the engraved information is so small and usually in discreet ( yet conspicuous ) places and blackened so that its hard if not impossible to tell what you have there unless you know what to look for. 1 1/4 inches of info in #4 font on the bottom a barrel is pretty hard to see if its barrel color.

Trust or traditional form 1? If you just want to keep your name off it go trust and use a generic trust name. Mine is (my initials+ trust ) . Good luck tracking me down from that.

I eFiled it on a Form1 under my trust, which has my name as part of the title.

Not so overly protective that I will not give my fist name when introduced to strangers, but in this new world I am getting leery of putting too much information out there. Don't want it appearing all over the internet with my trusts name on it because someone thought they needed a cell phone picture of it. Some anti might get a hold of the picture and scream holy terror, look at what this crazy gun nut built, how can this be legal? Don't want that floating around the HuffPost, Democratic Undergroud, etc. I am ok with it, and I will post pictures, without any personal identifying marks being shown. Yeah, I am one of those guys that block out my firearms serial number when I post a picture. I have had my identity stolen, and going through the process of fixing all that stuff was a PITA, making me a lot more cautious these days.