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Posted: 2/9/2018 4:19:30 PM EDT
I'm falling into murky waters here and I've hit some confusion on the engraving process for a Form 1 SBR. I'm getting several different answers, one of them from the ATF. I filed my Form 1 as an individual. They kicked it back because now, evidently, section 4h needs to be filled out. Now, on the engraving part, I'm being told that the lower receiver, now, does not need to be engraved with your name, city, and state UNLESS you are going to sell the SBR. On the other hand, I'm being told regardless that it still needs to be engraved. Anyone have any clarification on this? Also, any recommendations for some good engravers that actually do it to the correct depth and such?
Link Posted: 2/9/2018 2:04:54 PM EDT
[#1]
Quoted:
I'm falling into murky waters here and I've hit some confusion on the engraving process for a Form 1 SBR. I'm getting several different answers, one of them from the ATF. I filed my Form 1 as an individual. They kicked it back because now, evidently, section 4h needs to be filled out. Now, on the engraving part, I'm being told that the lower receiver, now, does not need to be engraved with your name, city, and state UNLESS you are going to sell the SBR. On the other hand, I'm being told regardless that it still needs to be engraved. Anyone have any clarification on this? Also, any recommendations for some good engravers that actually do it to the correct depth and such?
View Quote
You need to put your name/city/state on the BBL, frame or receiver, assuming you are using an existing firearm. Any of the usual engravers for firearms understand how to do this and can walk you through it. Try the Armory/SBR forum for engravers.
Link Posted: 2/9/2018 2:29:27 PM EDT
[#2]
YOU are the manufacturer of the SBR.  Regardless of the manufacturer markings already on the lower.  You HAVE to engrave Name, City, State on the lower.  Because if the ATF confronts you in the future about your NFA item (for whatever) the reason they will determine that you are the MFG of that item and thus subject to Chap 7 of the handbook.  It's stupid, it's murky but it covers your ass.

Reference: ATF NFA Handbook Chapter 7 "7.4.2(3)(4)"

Now 99.9% of the people, cops, and even the ATF you may run into regarding your SBR will not know or understand that you have to have it engraved because there is factory markings on it.

I shoot at a range where a lot of federal agents go to qual/train and have had several conversations with them about my NFA items.  The response I get the most is "Wow you made this SBR?".  The only person to ever ask for my paperwork was the owner of the range.
Link Posted: 2/9/2018 4:00:24 PM EDT
[#3]
You become the "manufacturer" if you're building it yourself.

You're not allowed to sell a Class III firearm to anyone other than through a Class III dealer. Whether that isn't your intention now or not, it has zero application IMO.

Veritas Machining
15450 US Highway 12
Union, MI 49103

You can find them on the web. Professional engraving service at reasonable prices. They'll walk you through the entire process.
Link Posted: 2/9/2018 4:03:54 PM EDT
[#4]
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Quoted:
You become the "manufacturer" if you're building it yourself.

You're not allowed to sell a Class III firearm to anyone other than through a Class III dealer. Whether that isn't your intention now or not, it has zero application IMO..
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Ignore this post. It is all wrong.
Link Posted: 2/9/2018 4:13:24 PM EDT
[#5]
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Quoted:
You become the "manufacturer" Maker if you're building it yourself.

You're not allowed to sell a Class III firearm to anyone other than through a Class III dealer IN NFA CONFIGURATION, if you replace the upper with a 16" barrel you can sell it to whomever you would like as title 1 firearm (same as transporting across state lines without a 5320.20).... Whether that isn't your intention now or not, it has zero application IMO.

Veritas Machining
15450 US Highway 12
Union, MI 49103

You can find them on the web. Professional engraving service at reasonable prices. They'll walk you through the entire process.
View Quote
FIFY

OP just spend the money to get it engraved, one less thing to worry about
Link Posted: 2/9/2018 4:23:29 PM EDT
[#6]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
You become the "manufacturer" if you're building it yourself.

You're not allowed to sell a Class III firearm to anyone other than through a Class III dealer. Whether that isn't your intention now or not, it has zero application IMO.

Veritas Machining
15450 US Highway 12
Union, MI 49103

You can find them on the web. Professional engraving service at reasonable prices. They'll walk you through the entire process.
View Quote
Wrong.  You're the maker of the Title II weapon.  You can sell it to whomever.  If you sell it instate (and no state law to the contrary) all you do is have the buyer fill out a form 4 and when it comes back approved do the transfer.  No FFL required.

If you sell out of state it has to go to an FFL in the buyers state with a Class 3 SOT, on a Form 4, who then transfers it to the buyer on a Form 4.
Link Posted: 2/9/2018 4:34:09 PM EDT
[#7]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
You become the "manufacturer" if you're building it yourself.

You're not allowed to sell a Class III firearm to anyone other than through a Class III dealer. Whether that isn't your intention now or not, it has zero application IMO.

Veritas Machining
15450 US Highway 12
Union, MI 49103

You can find them on the web. Professional engraving service at reasonable prices. They'll walk you through the entire process.
View Quote
You should know what you're talking about before spouting this stuff.
Link Posted: 2/9/2018 4:57:27 PM EDT
[#8]
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Quoted:

FIFY

OP just spend the money to get it engraved, one less thing to worry about
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Still wrong.  Ignore this post too
Link Posted: 2/9/2018 4:59:10 PM EDT
[#9]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
If you sell out of state it has to go to an FFL in the buyers state with a Class 3 SOT, on a Form 4, who then transfers it to the buyer on a Form 4.
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Still wrong.

Wow this is fun.
Link Posted: 2/9/2018 6:25:35 PM EDT
[#10]
Link Posted: 2/9/2018 10:31:38 PM EDT
[#11]
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Quoted:
Still wrong.

Wow this is fun.
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Quoted:
Quoted:
If you sell out of state it has to go to an FFL in the buyers state with a Class 3 SOT, on a Form 4, who then transfers it to the buyer on a Form 4.
Still wrong.

Wow this is fun.
What part of that is wrong?
Link Posted: 2/9/2018 11:11:27 PM EDT
[#12]
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Quoted:
What part of that is wrong?
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If you sell out of state it has to go to an FFL in the buyers state with a Class 3 SOT, on a Form 4, who then transfers it to the buyer on a Form 4.

1) It does not have to go to an FFL with an SOT. A non-SOT/FFL can receive it.
2) It can also go to a FFL in your state first, before sending out of state (costs $200 more).
3) SOT does not have to be 3, can also be 1/2 for example.
Link Posted: 2/18/2018 9:55:02 AM EDT
[#13]
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Quoted:
Both of these errors were pointed out in other posts, but not yours.

1. You are the maker, not manufacturer. Whole different set of procedures, regulations, and licenses.
2. You do not "HAVE" to engrave on the lower. Barrel is also completely acceptable, as is pistol slide if you're building a handgun-based NFA item.
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Quoted:
Quoted:
YOU are the manufacturer of the SBR.  Regardless of the manufacturer markings already on the lower.  You HAVE to engrave Name, City, State on the lower.
Both of these errors were pointed out in other posts, but not yours.

1. You are the maker, not manufacturer. Whole different set of procedures, regulations, and licenses.
2. You do not "HAVE" to engrave on the lower. Barrel is also completely acceptable, as is pistol slide if you're building a handgun-based NFA item.
If I go SBR, as the applicant, do I need to fill out the 4h section "additional description" (as the maker) ???
Link Posted: 2/18/2018 10:26:56 AM EDT
[#14]
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Quoted:
YOU are the manufacturer of the SBR.  Regardless of the manufacturer markings already on the lower.  You HAVE to engrave Name, City, State on the lower.  Because if the ATF confronts you in the future about your NFA item (for whatever) the reason they will determine that you are the MFG of that item and thus subject to Chap 7 of the handbook.  It's stupid, it's murky but it covers your ass.

Reference: ATF NFA Handbook Chapter 7 "7.4.2(3)(4)"

Now 99.9% of the people, cops, and even the ATF you may run into regarding your SBR will not know or understand that you have to have it engraved because there is factory markings on it.

I shoot at a range where a lot of federal agents go to qual/train and have had several conversations with them about my NFA items.  The response I get the most is "Wow you made this SBR?".  The only person to ever ask for my paperwork was the owner of the range.
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Your wrong.

Read the regs. You do not have to engrave the lower. You can engrave the barrel.  Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
Link Posted: 2/18/2018 11:06:38 AM EDT
[#15]
IN for the misinformation.
Link Posted: 2/18/2018 12:45:32 PM EDT
[#16]
Link Posted: 2/19/2018 3:03:27 AM EDT
[#17]
Here is the excerpt from the NFA handbook as well as the appropriate CFR.

As you are the "maker" of the NFA item, you are required to engrave the appropriate information.





§ 479.102 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.
Link Posted: 2/22/2018 5:21:54 PM EDT
[#18]
I’ve completed several Form 1’s, and I’ve always left “4H” blank without any being kicked back for corrections.  HOWEVER, on my most recent approved Form 1, the examiner did apply a stamp in red ink that reads, “Per 27 CFR 478.92 and 479.102, the maker must stamp the firearm with the maker’s name, city and state.

Sounds like the ATF is now cracking down on incomplete Form 1’s, which sucks because I just sent off a Form 1 a couple months ago and left 4H blank.
Link Posted: 3/9/2018 2:06:02 PM EDT
[#19]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
You do not have to engrave the lower. You can engrave the barrel.  Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
View Quote
 Seriously?  Anything to support that?  Wondering if I could engrave 1 barrel, and "install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.  Just doesn't sound like it would fly.

--Dan
Link Posted: 3/9/2018 11:04:44 PM EDT
[#20]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
 Seriously?  Anything to support that?  Wondering if I could engrave 1 barrel, and "install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.  Just doesn't sound like it would fly.

--Dan
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Quoted:
Quoted:
You do not have to engrave the lower. You can engrave the barrel.  Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
 Seriously?  Anything to support that?  Wondering if I could engrave 1 barrel, and "install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.  Just doesn't sound like it would fly.

--Dan
Like...about three posts above?

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
Link Posted: 3/10/2018 12:13:23 AM EDT
[#21]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
..."install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.
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I think this was the main part of Dan's question. I don't know the answer. Obviously this would leave him with no added engraving anywhere on his SBRs.

It's common for barrels to get swapped on imported Title I firearms, therefore eliminating their required import markings, but I'd expect Title II engraving to be more strict.

Would swapping the engraved barrel for an identical unmarked barrel be considered "removing" the NFA markings?
Link Posted: 3/10/2018 7:24:44 PM EDT
[#22]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
I think this was the main part of Dan's question. I don't know the answer. Obviously this would leave him with no added engraving anywhere on his SBRs.

It's common for barrels to get swapped on imported Title I firearms, therefore eliminating their required import markings, but I'd expect Title II engraving to be more strict.

Would swapping the engraved barrel for an identical unmarked barrel be considered "removing" the NFA markings?
View Quote
Like, reading comprehension.    Yes, looking for support of the notion that a barrel engraved for SBR requirement can be removed/replaced with one that is NOT engraved, assuming its installation still makes a SBR.  I find it difficult to believe ATF would be ok with this, hence my question.

--Dan
Link Posted: 3/10/2018 7:32:01 PM EDT
[#23]
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Quoted:

Like...about three posts above?
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Quoted:

Like...about three posts above?


Quoted:
Quoted:
You do not have to engrave the lower. You can engrave the barrel.  Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
 Seriously?  Anything to support that?  Wondering if I could engrave 1 barrel, and "install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.  Just doesn't sound like it would fly.

--Dan
There, maybe that helps .
Link Posted: 3/10/2018 10:37:53 PM EDT
[#24]
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Quoted:


There, maybe that helps .
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Quoted:
Quoted:

Like...about three posts above?


Quoted:
Quoted:
You do not have to engrave the lower. You can engrave the barrel.  Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
 Seriously?  Anything to support that?  Wondering if I could engrave 1 barrel, and "install" it once on each of 3 receivers I have a stamp for, then put whatever I want on without engraving the receivers.  Just doesn't sound like it would fly.

--Dan
There, maybe that helps .
Feel good with that?  Is this GD all of a sudden, or still a tech forum?

He's talking about moving Title II barrel between three registered lower receivers, and swapping in a Title I barrel onto the others, thus making them Title I firearms, and requiring no engraving.

An SBR is only and SBR when in an SBR configuration, and need only meet the engraving requirements of an SBR when in an SBR configuration.

A common practice in SBS Rem 870's is to engrave the SBS barrel only.  When in an SBS configuration, engraving requirements are met. When you swap on the 28" VR Skeet barrel, there's no unsightly engraving on the receiver.

This post brought to you with no snarky fonts or condescension.
Link Posted: 3/11/2018 2:15:32 AM EDT
[#25]
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Quoted:

Feel good with that?  Is this GD all of a sudden, or still a tech forum?
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Quoted:

Feel good with that?  Is this GD all of a sudden, or still a tech forum?
And yet you make snarky posts without addressing the question at hand.


He's talking about moving Title II barrel between three registered lower receivers, and swapping in a Title I barrel onto the others, thus making them Title I firearms, and requiring no engraving.
And you know this how?  I quoted the relevant part of his post.  He didn't mention Title I / II, taking it from SBR to non-SBR or anything about swapping the engraved barrel between registered receivers.  At all.  He said (paraphrasing here) you could engrave the barrel, then replace it without engraving the new one, but didn't say anything about length of the new barrel.  Which is why I asked for more information.
Link Posted: 3/11/2018 8:49:51 AM EDT
[#26]
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Quoted:

And you know this how?  I quoted the relevant part of his post.  He didn't mention Title I / II, taking it from SBR to non-SBR or anything about swapping the engraved barrel between registered receivers.  At all.  He said (paraphrasing here) you could engrave the barrel, then replace it without engraving the new one, but didn't say anything about length of the new barrel.  Which is why I asked for more information.
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Quoted:

And you know this how?  I quoted the relevant part of his post.  He didn't mention Title I / II, taking it from SBR to non-SBR or anything about swapping the engraved barrel between registered receivers.  At all.  He said (paraphrasing here) you could engrave the barrel, then replace it without engraving the new one, but didn't say anything about length of the new barrel.  Which is why I asked for more information.
Well, because it's in context with his post above which says:

Your[Sic] wrong.

Read the regs. You do not have to engrave the lower. You can engrave the barrel. Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
He's discussing the widely-held but incorrect belief that the receiver must be engraved.  He's offering an alternative engraving location ("you can engrave the barrel") and then discussing doing the "Title II/Title I Hokey Pokey."  via barrel swap.

In context, there's nothing to suggest he's recommending swapping Title II barrels and making an un-engraved SBR.
Link Posted: 3/11/2018 2:22:49 PM EDT
[#27]
Link Posted: 3/11/2018 5:20:06 PM EDT
[#28]
Discussion ForumsJump to Quoted PostQuote History
Quoted:

Going to have to disagree here. The question was not about swapping between Title I and II. It was about engraving the first barrel you attach, then swapping to a new barrel...leaving yourself with a firearm in an NFA configuration but without any maker's engravings.

Thought that was pretty clear, but evidently it wasn't to some people.
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Quoted:

Going to have to disagree here. The question was not about swapping between Title I and II. It was about engraving the first barrel you attach, then swapping to a new barrel...leaving yourself with a firearm in an NFA configuration but without any maker's engravings.

Thought that was pretty clear, but evidently it wasn't to some people.
Here's why I have to respectfully disagree with your interpretation.

In the post he was replying to, it was posted:

YOU are the manufacturer of the SBR. Regardless of the manufacturer markings already on the lower. You HAVE to engrave Name, City, State on the lower.
My emphasis added.

Gremlin then said:

Read the regs. You do not have to engrave the lower. You can engrave the barrel. Later down the road, you can replace that barrel with a new one and there is no requirements that you engrave this new barrel.
Again, my emphasis added.  This was a discussion of "must engraving be on the lower."  Although he doesn't mention a Title I barrel specifically, I think it takes a real extreme squint to make his post read that he supports a Title II weapon with no engraving.

That's what I meant by taking his post in context.  There's certainly nothing else from him supporting the "non-engraving" position.

I guess only Gemlin can put it to rest.  Calling @Gemlin
Link Posted: 3/13/2018 4:47:59 PM EDT
[#29]
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Quoted:
Like, reading comprehension.    Yes, looking for support of the notion that a barrel engraved for SBR requirement can be removed/replaced with one that is NOT engraved, assuming its installation still makes a SBR.  I find it difficult to believe ATF would be ok with this, hence my question.

--Dan
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Quoted:
I think this was the main part of Dan's question. I don't know the answer. Obviously this would leave him with no added engraving anywhere on his SBRs.

It's common for barrels to get swapped on imported Title I firearms, therefore eliminating their required import markings, but I'd expect Title II engraving to be more strict.

Would swapping the engraved barrel for an identical unmarked barrel be considered "removing" the NFA markings?
Like, reading comprehension.    Yes, looking for support of the notion that a barrel engraved for SBR requirement can be removed/replaced with one that is NOT engraved, assuming its installation still makes a SBR.  I find it difficult to believe ATF would be ok with this, hence my question.

--Dan
@ScottS , I think this is the post that has been skipped over in the discussion of Title 1 vs 2 and barrel swapping.  Bold is my emphasis.
Link Posted: 3/13/2018 4:58:00 PM EDT
[#30]
Your NFA item must be engraved with your info while it's in NFA configuration.  So removing the engraved barrel and replacing it with an unengraved short barrel isn't kosher.
Link Posted: 3/13/2018 5:46:58 PM EDT
[#31]
It is pretty much accepted that engraving the makers info on the receiver of an AR is proper. If you do it different than the accepted method, whether technically legal or maybe not,  is inviting scrutiny that might lead to loss of property and large legal fees. I don't know about you, but just going out in public with an SBR and can makes for scrutiny by those not in the know. My SBR is engraved.
Link Posted: 3/13/2018 5:53:42 PM EDT
[#32]
Engraving the barrel is an accepted and proper method. It's been done that way for a long time. (Yes, receiver engraving is more common.)
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