Looks like there's another twist in the SBR markings drama, this may be the final verdict.  Check it out here:B.A.T.F.E.'s latest response.  ARKAR

This letter only makes things more confusing (got to love the gov't).  It states their original opinion was correct, but then it goes on to state that they were "remiss" in advising that the maker is required to identify the firearm with his or her name.

Doesn't that contradict the earlier statement?  WTF?  hy
Geeez.

Until I see something concrete otherwise, I'm not going to mark up mine.  I contacted my C3 dealer and they said that this discussion always seems to come up, only with no clear guidance--so they don't mark.

As clear as mudd. Protect yourself, mark your SBR.

look at the bottom.... frame, recever, OR barrel ..?

barrel...?  am i missing somthing..

Quoted: look at the bottom.... frame, recever, OR barrel ..? barrel...?  am i missing somthing..

Right, and he uses the word "can" on all three.  Why can't the BATF make up their mind and use the word "must" place on either frame, receiver, or barrel?  

I'm actually more confused now that they made it all clear...  

What the BATF is saying is you are modifying an existing weapon with markings...manuf,caliber,model, etc...and to put these desriptions on your registration form. Use the existing s/n as its s/n, send in the paperwork and do not modify until approved. basically what you are doing is transcribing the original description of the gun from the original manufacturer and just changing the barrel length and overall length. If you were to start from a blank unmarked gun, then you would need to add your name as the manufacturer, such as what was done originally. The paperwork needs a description of the manufacturer on its form, all you are doing is changing its barrel length and overall length and then putting the change on paper.  When saleen modifies a mustang, the title remains the same-mustang- but the car has saleen written all over it! Your name is registered to  the firearm on the paperwork. Example- a shotgun with the barrel changed to under the legal limit-18", this is now a short barreled shotgun and needs to be registered, all you did was change a barrel, could even be the same manufacturer for the barrel. The paperwork would describe the gun and be registered to you, without stamping you name all over it.

What the BATF is saying is you are modifying an existing weapon with markings...manuf,caliber,model, etc...and to put these desriptions on your registration form. Use the existing s/n as its s/n, send in the paperwork and do not modify until approved. basically what you are doing is transcribing the original description of the gun from the original manufacturer and just changing the barrel length and overall length. If you were to start from a blank unmarked gun, then you would need to add your name as the manufacturer, such as what was done originally. The paperwork needs a description of the manufacturer on its form, all you are doing is changing its barrel length and overall length and then putting the change on paper.  When saleen modifies a mustang, the title remains the same-mustang- but the car has saleen written all over it! Your name is registered to  the firearm on the paperwork. Example- a shotgun with the barrel changed to under the legal limit-18", this is now a short barreled shotgun and needs to be registered, all you did was change a barrel, could even be the same manufacturer for the barrel. The paperwork would describe the gun and be registered to you, without stamping you name all over it.

Quoted: What the BATF is saying is you are modifying an existing weapon with markings...manuf,caliber,model, etc...and to put these desriptions on your registration form. Use the existing s/n as its s/n, send in the paperwork and do not modify until approved. basically what you are doing is transcribing the original description of the gun from the original manufacturer and just changing the barrel length and overall length. If you were to start from a blank unmarked gun, then you would need to add your name as the manufacturer, such as what was done originally. The paperwork needs a description of the manufacturer on its form, all you are doing is changing its barrel length and overall length and then putting the change on paper.  When saleen modifies a mustang, the title remains the same-mustang- but the car has saleen written all over it! Your name is registered to  the firearm on the paperwork. Example- a shotgun with the barrel changed to under the legal limit-18", this is now a short barreled shotgun and needs to be registered, all you did was change a barrel, could even be the same manufacturer for the barrel. The paperwork would describe the gun and be registered to you, without stamping you name all over it.

As if guns are treated like cars.  Here's an idea:  Why doesn't someone submit a Form-1 with the EXISTING make/model/SN and post what happens.  IF the thing gets approved, no need to make any additional markings, as they will exactly match what the Form-1 says.  If they shit the form back to you, then you can either do what they say, or have them send you a check and forget the whole thing.

Who's feelin' froggy?

Well, I'll be dipped in shit.  How about this from the actual instructions for the Form-1?:

Serial Numbers and other Markings. If an existing firearm is being modified into an NFA firearm, enter the existing serial number of the firearm into item 4g and the name and address of the original manufacturer into item 4a. Do not Alter or Modify the Existing Serial Number. If the NFA firearm is being made from parts, your name and address are to be entered into 4a and a serial number you create is to be entered into item 4g.

Note the word "modified" is used.  Not "made", when referring to registering a non-NFA firearm as an NFA firearm.

However, it also says this:

Make. The term “make”, and the various derivatives of such word, shall include manufacturing (other than by one qualified to engage in such business under the NFA), putting together, altering, any combination of these, or otherwise producing a fiream.

But since they make the semantic distinction using "modified" instead of "made" in the previous section, I think just using the existing info is correct.  And I don't think "modify" is a derivitive of "make".  "Modify" is closer to "change" or "alter".

I'm just going by what the form says, which should override any various opinions stated by ATF employees.  That said, I still stand by my advice for someone to simply fill it out with the existing data and see what happens...

Quoted: Well, I'll be dipped in shit.  How about this from the actual instructions for the Form-1?: Serial Numbers and other Markings. If an existing firearm is being modified into an NFA firearm, enter the existing serial number of the firearm into item 4g and the name and address of the original manufacturer into item 4a. Do not Alter or Modify the Existing Serial Number. If the NFA firearm is being made from parts, your name and address are to be entered into 4a and a serial number you create is to be entered into item 4g. Note the word "modified" is used.  Not "made", when referring to registering a non-NFA firearm as an NFA firearm. However, it also says this: Make. The term “make”, and the various derivatives of such word, shall include manufacturing (other than by one qualified to engage in such business under the NFA), putting together, altering, any combination of these, or otherwise producing a fiream. But since they make the semantic distinction using "modified" instead of "made" in the previous section, I think just using the existing info is correct.  And I don't think "modify" is a derivitive of "make".  "Modify" is closer to "change" or "alter". I'm just going by what the form says, which should override any various opinions stated by ATF employees.  That said, I still stand by my advice for someone to simply fill it out with the existing data and see what happens...

Here's what happens - My Form 1 that was just approved a couple of months ago has "NONE" in 4h.  What goes here?? Answer is "...ALL numbers and other identifying data which will appear on the firearm."  If ALL is NONE, where does an additional name and address fit in?  My BTAFE approval provides that no additional markings appear on the firearm.

Quoted: Quoted: What the BATF is saying is you are modifying an existing weapon with markings...manuf,caliber,model, etc...and to put these desriptions on your registration form. Use the existing s/n as its s/n, send in the paperwork and do not modify until approved. basically what you are doing is transcribing the original description of the gun from the original manufacturer and just changing the barrel length and overall length. If you were to start from a blank unmarked gun, then you would need to add your name as the manufacturer, such as what was done originally. The paperwork needs a description of the manufacturer on its form, all you are doing is changing its barrel length and overall length and then putting the change on paper.  When saleen modifies a mustang, the title remains the same-mustang- but the car has saleen written all over it! Your name is registered to  the firearm on the paperwork. Example- a shotgun with the barrel changed to under the legal limit-18", this is now a short barreled shotgun and needs to be registered, all you did was change a barrel, could even be the same manufacturer for the barrel. The paperwork would describe the gun and be registered to you, without stamping you name all over it. As if guns are treated like cars.  Here's an idea:  Why doesn't someone submit a Form-1 with the EXISTING make/model/SN and post what happens.  IF the thing gets approved, no need to make any additional markings, as they will exactly match what the Form-1 says.  If they shit the form back to you, then you can either do what they say, or have them send you a check and forget the whole thing. Who's feelin' froggy?

I did just that.  Had a Carbon15 lower, submitted my Form 1 using all the markings from the lower itself, and it was approved.  I have been the happy owner of a Carbon15 97s for quite some time now.

Quoted: Quoted: Quoted: What the BATF is saying is you are modifying an existing weapon with markings...manuf,caliber,model, etc...and to put these desriptions on your registration form. Use the existing s/n as its s/n, send in the paperwork and do not modify until approved. basically what you are doing is transcribing the original description of the gun from the original manufacturer and just changing the barrel length and overall length. If you were to start from a blank unmarked gun, then you would need to add your name as the manufacturer, such as what was done originally. The paperwork needs a description of the manufacturer on its form, all you are doing is changing its barrel length and overall length and then putting the change on paper.  When saleen modifies a mustang, the title remains the same-mustang- but the car has saleen written all over it! Your name is registered to  the firearm on the paperwork. Example- a shotgun with the barrel changed to under the legal limit-18", this is now a short barreled shotgun and needs to be registered, all you did was change a barrel, could even be the same manufacturer for the barrel. The paperwork would describe the gun and be registered to you, without stamping you name all over it. As if guns are treated like cars.  Here's an idea:  Why doesn't someone submit a Form-1 with the EXISTING make/model/SN and post what happens.  IF the thing gets approved, no need to make any additional markings, as they will exactly match what the Form-1 says.  If they shit the form back to you, then you can either do what they say, or have them send you a check and forget the whole thing. Who's feelin' froggy? I did just that.  Had a Carbon15 lower, submitted my Form 1 using all the markings from the lower itself, and it was approved.  I have been the happy owner of a Carbon15 97s for quite some time now.

That's proof enough for me.  Still, I can't shake the feeling that if I don't do it one day it's gonna bite me in the ass.  

The idea behind making and modifying etc.. is the receiver of the gun not its parts. the receiver is the registered part, all else can be changed at anytime in its life time. Altering the receiver is what is meant, not the barrel. You can not change the receiver which is the registered part. If you want to cut a barrel down..good ...it is not the receiver. Suppose a barrel gets warn out? do you replace the barrel or replace the receiver? when the barrel is replaced it has its own markings or not. Remember- if you manfacture a weapon, you must mark it...it has a receiver.......but if you modify a part, not the receiver, you are not a manufacturer.  by the way...I have had sbr (s) registered  

Quoted: The idea behind making and modifying etc.. is the receiver of the gun not its parts. the receiver is the registered part, all else can be changed at anytime in its life time. Altering the receiver is what is meant, not the barrel. You can not change the receiver which is the registered part. If you want to cut a barrel down..good ...it is not the receiver. Suppose a barrel gets warn out? do you replace the barrel or replace the receiver? when the barrel is replaced it has its own markings or not. Remember- if you manfacture a weapon, you must mark it...it has a receiver.......but if you modify a part, not the receiver, you are not a manufacturer.  by the way...I have had sbr (s) registered

In keeping with the discussion, so....  did you engrave your lowers?

no, the lowers are already marked by the manufacturer

Well, This is confusing as hell, just as before.  I have two krinkov kits I want to do as SBR's, and I am just waiting on the receivers so I can fill out the paperwork.  

Does anyone have the original letter they can post from the ATF so we can see what they said in the orginal letter?

Also, has anyone thought of calling the guy from the ATF who wrote the letter and ask him what we are required to put on our SBRs?  I'll call him, but it will probably be a few days before I get some free time to do it while they are open.  I am used to dealing with the FAA, and sometimes you just have to get on the phone and ask them, of course, the problem though is that even people within the organization interperate regulations differently.

My delemia, I have two 100% receivers on the way.  They will be marked with the original manufactures serial# name, place of manufacture.  So when I want to then register the receivers for SBR to build my krink kits on, can I just use the original manufactors information on the FORM 1 (which seams to work)?  

The next real question is, Am I, the person who is regestering the receiver for SBR under a Form 1, required to engrave my name and information anywhere on the firearm?

Hopefully we can get a real answer soon.  


Also, I have a question for filling out the Form 1 for those of you who have done it already.  For box 4.f. overall length, if the rifle has a collapsing or folding stock do you put the length with the stock folded or extended or does it matter?

Quoted: Well, This is confusing as hell, just as before.  I have two krinkov kits I want to do as SBR's, and I am just waiting on the receivers so I can fill out the paperwork.   Does anyone have the original letter they can post from the ATF so we can see what they said in the orginal letter? Also, has anyone thought of calling the guy from the ATF who wrote the letter and ask him what we are required to put on our SBRs?  I'll call him, but it will probably be a few days before I get some free time to do it while they are open.  I am used to dealing with the FAA, and sometimes you just have to get on the phone and ask them, of course, the problem though is that even people within the organization interperate regulations differently. My delemia, I have two 100% receivers on the way.  They will be marked with the original manufactures serial# name, place of manufacture.  So when I want to then register the receivers for SBR to build my krink kits on, can I just use the original manufactors information on the FORM 1 (which seams to work)?   The next real question is, Am I, the person who is regestering the receiver for SBR under a Form 1, required to engrave my name and information anywhere on the firearm? Hopefully we can get a real answer soon.   Also, I have a question for filling out the Form 1 for those of you who have done it already.  For box 4.f. overall length, if the rifle has a collapsing or folding stock do you put the length with the stock folded or extended or does it matter?

Use original manufacturer identification...4a on form 1     note; it says "receiver" which means manufactured previous to assembly. do not modify receiver.

need not to engrave, manufacturer is on receiver. the receiver has been registered as a weapon. as stated in the BATF letter in this thread, it says you can mark the gun, but note it says "or" the barrel..which can be changed, not the receiver which is the registered part. so why mark it?  just the ATF trying to get un-needed
information when not required
you are assembling a weapon and modifying it to a sbr

use length with full extended stock as overall

Quoted: Quoted: Use original manufacturer identification...4a on form 1     note; it says "receiver" which means manufactured previous to assembly. do not modify receiver. need not to engrave, manufacturer is on receiver. the receiver has been registered as a weapon. as stated in the BATF letter in this thread, it says you can mark the gun, but note it says "or" the barrel..which can be changed, not the receiver which is the registered part. so why mark it?  just the ATF trying to get un-needed information when not required you are assembling a weapon and modifying it to a sbr use length with full extended stock as overall

Thanks.  Thats what I thought.  Hopefully my receivers will get here soon so I can get this paperwork sent in.

I don't see what the big deal of putting your info on an SBR is. Heck, SBR's don't have much resale value, so people should plan on keeping them forever anyway. In the event of theft, you'd probably be glad that your personal info is on there...

If you were supposed to use the original manufacturer's markings on the forms, then why did the government specifically say that persons making machineguns before the '86 ban had to mark their info on them?

It does not matter if you are making a Title 2 firearm from scratch or are converting an existing Title 1 firearm. The definition of "firearm" in the law cited below only includes NFA items. Existing Title 1 firearms are not "firearms" for the purpose of this law.

The person submittting the Form 1 is the maker. If you are making the SBR from an existing Title 1 firearm, you will be simply reusing some of the existing markings: serial number, model, and caliber.

What is left for you to add are the remaining required markings: your name and address. You are required to do this by law, regardless of what you put or didn't put on your Form 1.

I've highlighted in red the parts that spell out the required markings that the maker of a Title 2 firearm must apply to the firearm.



NFA marking requirements

[Code of Federal Regulations] [Title 27, Volume 1] [Revised as of April 1, 2002] From the U.S. Government Printing Office via GPO Access [CITE: 27CFR179.102] [Page 1218-1219]            TITLE 27--ALCOHOL, TOBACCO PRODUCTS AND FIREARMS CHAPTER I--BUREAU OF ALCOHOL, TOBACCO AND FIREARMS, DEPARTMENT OF THE                                TREASURY PART 179--MACHINE GUNS, DESTRUCTIVE DEVICES, AND CERTAIN OTHER FIREARMS--Table of Contents         Subpart G--Registration and Identification of Firearms Sec. 179.102  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 [[Page 1219]]    (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. (Approved by the Office of Management and Budget under control number 1512-0550) [T.D. ATF-461, 66 FR 40601, Aug. 3, 2001]

I have spoke with NFA abotu this and i was told to mesure the overall lenght with the stock fully extended . hope that helps