Serial Number question

Balrog

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Nov 28, 2008
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I am trying to find a copy of the requirements for placing serial numbers on handguns by manufacturers. From what I can tell, the serial number has to be placed on the frame or receiver. Is that correct?
 
Yes that would be correct along with the size and depth requirements. When it comes to polymer frames, the serial number must be engraved on some type of metal plate that is not removable. Glock and Glock clones are just one example of this where the serial number plate is molded into the bottom of the frame. Kel-Tec likes to put their serial numbers on a plate right below the hammer/striker on their pistols.

You didn't say what type of frame you are engraving so that is why I mentioned the requirements for polymer frames. Engraving a serial number directly into the polymer is not acceptable for manufacturers. IIRC New Frontier Arms got into trouble years ago for not using a metal plate that was properly molded into the receiver on the NFA polymer AR lowers.
 
Yes that would be correct along with the size and depth requirements. When it comes to polymer frames, the serial number must be engraved on some type of metal plate that is not removable. Glock and Glock clones are just one example of this where the serial number plate is molded into the bottom of the frame. Kel-Tec likes to put their serial numbers on a plate right below the hammer/striker on their pistols.

You didn't say what type of frame you are engraving so that is why I mentioned the requirements for polymer frames. Engraving a serial number directly into the polymer is not acceptable for manufacturers. IIRC New Frontier Arms got into trouble years ago for not using a metal plate that was properly molded into the receiver on the NFA polymer AR lowers.

So how does Sig get around the requirement by putting the serial number of the interchangeable fire control unit? The FCU is not a receiver, nor is it a frame, is it?
 
I suppose the FCU is considered the "gun" in this case. It makes sense otherwise you couldn't swap stocks on rilfes or shotguns.
 
With the Sig P320/M17, etc. the FCU is considered the actual frame as far as the ATF is concerned since it holds the trigger and needed fire control parts. A serial number must be engraved on the FCU in this case.
 
With the Sig P320/M17, etc. the FCU is considered the actual frame as far as the ATF is concerned since it holds the trigger and needed fire control parts. A serial number must be engraved on the FCU in this case.

I am sure lawyers for Sig would have made sure that there is no other way to interpret the law regarding serial numbering, but with the recent ATF rule change regarding pistol braces, and the resulting reclassification of pistols as rifles, I would just be concerned that on another whim, the ATF could decide that a FCU is not a frame (ie, gun), but rather a part. How is the FCU really any different than a drop in trigger group for an AR?
 
I am sure lawyers for Sig would have made sure that there is no other way to interpret the law regarding serial numbering, but with the recent ATF rule change regarding pistol braces, and the resulting reclassification of pistols as rifles, I would just be concerned that on another whim, the ATF could decide that a FCU is not a frame (ie, gun), but rather a part. How is the FCU really any different than a drop in trigger group for an AR?

None of the recent ATF rule changes effect the Sig FCU. None of us can tell what the future might bring, but as of right now a Sig fire control unit IS the frame according to the ATF. I have yet to see a "rifle" module that accepts the Sig FCU and until that happens it is a moot point.
 
The Ruger Mk IV series pistols have the serial numbers on the receiver, not the frame. So when I bought additional uppers from Volquartsen for $25, I had to go through an FFL for each one. So the cost was close to $100 each when everything was said and done.

I do know in Ca the serials must be engraved in metal, which is why the serials are on metal tabs in a Glock frame, for example.

Stay safe.
 
None of the recent ATF rule changes effect the Sig FCU. None of us can tell what the future might bring, but as of right now a Sig fire control unit IS the frame according to the ATF. I have yet to see a "rifle" module that accepts the Sig FCU and until that happens it is a moot point.
Yes, i agree, just concerned that arbitrary changes could come. I am just not sure how a Sig FCU is different from a drop in trigger really, and would hate for someone with a political agenda to decide they don't want people to have the modularity that the FCU allows, and require SN's on all the grip modules.

From what I can gather, the law says SN need to be on frame or receiver, and while some might decide a FCU is a frame, others may not. It seems subjective.
 
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just concerned that arbitrary changes could come
So let's not be "concerned" until the "change" happens, if it ever happens (See ATF response below).

someone with a political agenda to decide they don't want people to have the modularity that the FCU allows
Just as First Amendment allows modern forms of free speech/communication like email/text as ruled over and over by the Supreme Court, Second Amendment is not a "second class right" and also allows modern types of "arms" like stun guns/magazine fed semi-auto firearms as ruled by Supreme Court in Caetano v Mass/Heller.

Instead of being concerned, I welcome "modernization" of arms such as scopes/red dot/fiber optic sights to help those with visual disability, bipod/monopod/stabilization brace to help those with physical disability, ambidextrous controls for left-handed shooters, adaptive devices/enlarged/lightened controls to help those with hand dexterity issues/disability and suppressors to protect hearing of shooters and those nearby, etc.

So how does Sig get around the requirement by putting the serial number of the interchangeable fire control unit? The FCU is not a receiver, nor is it a frame, is it?
This is from sigtalk.com - https://www.sigtalk.com/threads/p320-fcu-legal-question.98241/#post-1264193

This is in regards to your recent email to the Firearms Industry Programs Branch (FIPB) of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) seeking information on the Sig Model P320 "fire control unit" (FCU). Specifically, you wish to know if the FCU can be installed in any other Sig P320 pistol and sold or if it must stay with the original "pistol" it came with. You point out in your email that the FCU is the only part of the firearm which is serialized.

As background, the Gun Control Act (GCA), 18 U.S.C. § 921(a)(3), defines the term “firearm” as—

…(A) any weapon (including a starter gun), which will, or is designed to or may readily be converted to expel a projectile by the action of an explosive; (B) the frame or receiver of any such weapon; (C) any firearm muffler or firearm silencer; (D) any destructive device. Such term does not include an antique firearm.

The item that Sig Sauer refers to as the FCU is in fact the frame of the firearm and thus is the regulated item and a firearm as defined above in and of itself (thus the reason it bears the serial number).

All the other component parts of the firearm are simply firearms parts and their domestic sale and possession are thus unregulated. You may assemble / combine the FCU with any Sig Sauer P320 parts you wish only the FCU itself is regulated.

As noted the FCU all by itself is a "firearm" as defined and must be sold and transferred as such.

We thank you for your inquiry and trust that the foregoing has been responsive.

Michael S Knapp
Program Manager
Bureau of Alcohol, Tobacco, Firearms and Explosives Firearms and Explosives
Industry Division Firearms Industry Programs Branch
 
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So let's not be "concerned" until the "change" happens, if it ever happens (See ATF response below).


Just as First Amendment allows modern forms of free speech/communication like email/text as ruled over and over by the Supreme Court, Second Amendment is not a "second class right" and also allows modern types of "arms" like stun guns/magazine fed semi-auto firearms as ruled by Supreme Court in Caetano v Mass/Heller.

Instead of being concerned, I welcome "modernization" of arms such as scopes/red dot/fiber optic sights to help those with visual disability, bipod/monopod/stabilization brace to help those with physical disability, ambidextrous controls for left-handed shooters, adaptive devices/enlarged/lightened controls to help those with hand dexterity issues/disability and suppressors to protect hearing of shooters and those nearby, etc.


This is from sigtalk.com - https://www.sigtalk.com/threads/p320-fcu-legal-question.98241/#post-1264193

This is in regards to your recent email to the Firearms Industry Programs Branch (FIPB) of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) seeking information on the Sig Model P320 "fire control unit" (FCU). Specifically, you wish to know if the FCU can be installed in any other Sig P320 pistol and sold or if it must stay with the original "pistol" it came with. You point out in your email that the FCU is the only part of the firearm which is serialized.

As background, the Gun Control Act (GCA), 18 U.S.C. § 921(a)(3), defines the term “firearm” as—

…(A) any weapon (including a starter gun), which will, or is designed to or may readily be converted to expel a projectile by the action of an explosive; (B) the frame or receiver of any such weapon; (C) any firearm muffler or firearm silencer; (D) any destructive device. Such term does not include an antique firearm.

The item that Sig Sauer refers to as the FCU is in fact the frame of the firearm and thus is the regulated item and a firearm as defined above in and of itself (thus the reason it bears the serial number).

All the other component parts of the firearm are simply firearms parts and their domestic sale and possession are thus unregulated. You may assemble / combine the FCU with any Sig Sauer P320 parts you wish only the FCU itself is regulated.

As noted the FCU all by itself is a "firearm" as defined and must be sold and transferred as such.

We thank you for your inquiry and trust that the foregoing has been responsive.

Michael S Knapp
Program Manager
Bureau of Alcohol, Tobacco, Firearms and Explosives Firearms and Explosives
Industry Division Firearms Industry Programs Branch

I get what you are saying, but given recent developments, it is naive to think that what is said in a communication like that really matters or bears long term legal weight. Someone else comes along and just decides something different, and your FCU goes from being a frame to a part.
 
I get what you are saying, but given recent developments, it is naive to think that what is said in a communication like that really matters or bears long term legal weight. Someone else comes along and just decides something different, and your FCU goes from being a frame to a part.
We have plenty of things that have ACTUALLY happened to be concerned with.

I personally don't have the time/energy to worry about things that hasn't happened or may never happen. If what you are "concerned" with happens, sure, we can certainly go from there. Until then, let's focus on things that have already happened and happening.

In 2023 with countless attack on 2A we are legally battling in countless courts at state/federal levels, we need to come together and pull our resources to fund these challenges.

Peace.

BTW, this was the OP:
requirements for placing serial numbers on handguns by manufacturers.

From what I can tell, the serial number has to be placed on the frame or receiver. Is that correct?
 
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@LiveLife summed it up fairly well and easily understood. As noted the Sig FCU is the serialized portion and as such it is the frame as far as the ATF is concerned.
 
But why worry about it. It was clearly stated in the frame and receiver rule change in 2021 that the Sig FCU is the serialized frame. If you are going to worry about this then you might as well worry about the government coming to take ALL of your firearms.

As far as I am concerned your question was answered and there is no need for further discussion.
 
But why worry about it. It was clearly stated in the frame and receiver rule change in 2021 that the Sig FCU is the serialized frame. If you are going to worry about this then you might as well worry about the government coming to take ALL of your firearms.

As far as I am concerned your question was answered and there is no need for further discussion.

Well I do worry about government coming to take guns. They won't do it in one swoop, nor will it likely happen by legislation in Congress that is signed by the President. It will more likely come incrementally from the slow but persistent reinterpretation of laws, redefining terms as needed, by the non-elected officials that run the government bureaucracy.
 
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