i have two 80% lowers.  They are done and functional firearms.  I am hoping to give them to my daughters when they grow up with custom serial numbers.  So, I would like to engrave them and cerakote them.  The local gun store I want to use is a manufacturer who also does cerakoting and engraving.  Is it legal for them to engrave and cerakote a finished 80% lower?  The owner wasn't sure about how to enter it into his logbook since it is an unmarked lower.  Ideas?  Help?  Suggestions?

there are very conflicting opinions on this matter right now due to atf ruling 2015-1

The debate is whether or not those services performed to a completed 80% constitute "manufacturing." If it is, then the shop performing the work needs to have an 07/02 and they would have to engrave their info into the reciever. i know many gunsmiths are refusing the work as its a grey area that could cost them dearly if the ATF comes at them.

now IMO, this isn't manufacturing as long as two things are covered. 1) the 80% has been completed into a fully functioning firearm and 2) there is no transfer taking place.

As far as how to record it in their book, it would be the same as a pre 1964?? firearm with no serial number

FWIW my Cerakote guy has no problem doing 80% lowers with no markings. I'd imaging that engraving is legally "gunsmithing" just like Cerakoting is.

anyone else want to jump in on this topic?

If they are already functional firearms, then any work done on them is gunsmithing, not manufacturing.

I would take photos to prove that they are complete and unmarked, just in case the question comes up.

Engraving of a firearm is explicitly identified as NOT being a manufacturing process: "However, none of the enumerated processes (i.e., repairing, modifying, embellishing, refurbishing, installing parts, or specialized finishing) actually create a frame or receiver, or make an existing frame or receiver suitable for use in assembling a “weapon” capable of expelling a projectile" . . .

HOWEVER, this only protects a licensed gunsmith.  A NON-licensed person should only engrave blanks BEFORE the process of machining out the trigger group cavity.

When I had mine done I was told by the owner at my lgs that the engraving was just that and nothing was required. Cerakoting is considered manufacturing however. So, I had to have some sort of serial number engraved. Not sure exactly how accurate that is but to cover their asses they used a dremel and put C01 on it where it would be covered by my grip. Hope this helps. I ended up having a custom serial number engraved anyways.