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1/3/2014 7:21:09 AM EDT
I already have one "pre-ban" (I'm stuck in MA right now) Colt AR lower engraved and registered as an SBR and I have several uppers I use on it. I recently built one of the most fun, and surprisingly accurate for what it is, uppers using an Oly OA-93 pistol barrel. It's so much fun I'm going to dedicate another SBR lower just to that upper.

The only other pre-bans I have are a pair of Colt SP-1's, one Carbine and one Rifle. I don't want to engrave an SP-1 and I know you can engrave the barrel instead. That would work since I'm using only one upper, but there's no barrel area large enough to engrave exposed. Can I legally engrave the upper receiver instead, or does it have to be the lower or barrel only?
1/3/2014 9:39:28 AM EDT
[#1]
IMO you can mark on the upper receiver.
Here is what I am basing this off of.
I'm sure if I'm wrong I will be corrected.

Sec. 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:
View Quote


In conjunction with this letter.

1/3/2014 2:13:00 PM EDT
[#2]
The wording of the letter and the law make it sound like I can engrave the upper, since it is a "receiver". Thanks for posting this.
1/3/2014 3:56:58 PM EDT
[#3]
It is not a receiver based on ATF definition.
1/3/2014 4:23:19 PM EDT
[#4]
***EDITED***
Well, I just did a little measuring with my digital calipers. My friend has a CNC milling machine in his garage and does all of my NFA engraving for me. He does a great job. He can do engraving on the circumference of something, like the barrel of my AR SBR. He did the engraving on my Ruger 10/22 SBR the minimum size the ATF requires. I checked and it WILL fit in the exposed space between the FSB. I'll have to come up with another side mount for my sling but that's OK. It's going to be a pain having to keep rotating the barrel in the vise on the mill since it's going to take four lines to get my name, city and state on there but that's OK. I'll do the extra work if it means I can avoid engraving my SP-1.

********************************************************************************

Well, I'll have to work on a way to engrave the barrel then. I may engrave it on the top of the barrel and mill a groove in the handguard so it's visible. I just can't bring myself to engrave an SP-1 lower.

The only exposed barrel would be the space between the bottom of the FSB. Too bad it's not enough room. I think the groove in the handguard is the only way. With the groove it would not have to be "disassembled" so it should be legal.

Here is the upper in question mounted on my current SBR's Colt Sporter lower. Any other ideas?



1/4/2014 2:56:49 PM EDT
[#5]
Quote History
Quoted:
The wording of the letter and the law make it sound like I can engrave the upper, since it is a "receiver". Thanks for posting this.
View Quote


The receiver is the part of the gun with a serial number. An upper or bbl. does not have a serial number.
1/4/2014 3:45:01 PM EDT
[#6]
Quote History
Quoted:


The receiver is the part of the gun with a serial number. An upper or bbl. does not have a serial number.
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Quoted:
Quoted:
The wording of the letter and the law make it sound like I can engrave the upper, since it is a "receiver". Thanks for posting this.


The receiver is the part of the gun with a serial number. An upper or bbl. does not have a serial number.


I agree that there's no serial number on the barrel, but the ATF letter clearly states in the last paragraph that the Maker's Name, City and State can be engraved on the barrel.
1/5/2014 7:35:00 AM EDT
[#7]
Quote History
Quoted:


I agree that there's no serial number on the barrel, but the ATF letter clearly states in the last paragraph that the Maker's Name, City and State can be engraved on the barrel.
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Quoted:
Quoted:
Quoted:
The wording of the letter and the law make it sound like I can engrave the upper, since it is a "receiver". Thanks for posting this.


The receiver is the part of the gun with a serial number. An upper or bbl. does not have a serial number.


I agree that there's no serial number on the barrel, but the ATF letter clearly states in the last paragraph that the Maker's Name, City and State can be engraved on the barrel.



Does that letter state it is SPECIFICALLY for a rifle that has a readily removeable barrel/ Upper?  Do not split hairs with the ATF.

And for god sakes, the engraving is so damn small, nobody will notice it on the lower anyway. One if mine is marked on the front of the magwell, After I aluma blacked it, it is hard to see.
1/5/2014 8:43:32 AM EDT
[#8]
I'll submit a letter to the ATF and wait for a response. It's not like approvals are coming through quickly anyway.

As for the size not being noticeable, this is the minimum size according to the ATF. I'd have to say it's noticeable!

1/5/2014 8:52:38 AM EDT
[#9]
The Maker markings can be on the barrel. They have to be conspicuous so that they can be seen without disassembling the weapon. There is no size requirement for the maker markings, only a .003" depth requirement. Only the serial number has a height (1/16") and depth (.003") requirement


Title 27: Alcohol, Tobacco and Firearms

§ 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.
1/5/2014 8:56:10 AM EDT
[#10]
Quote History
Quoted:
The Maker markings can be on the barrel. They have to be conspicuous so that they can be seen without disassembling the weapon. There is no size requirement for the maker markings, only a .003" depth requirement. Only the serial number has a height (1/16") and depth (.003") requirement

View Quote



This. Don't waste time writing letters.

It is amazing how small it can be with a quality cutter/laser.
1/5/2014 11:20:04 AM EDT
[#11]
Thanks. I'll engrave it in the space left between the front and rear ring of the FSB. There's even enough room there, just barely, with 1/8" letters.

Since this is the case I think I'll just go ahead and SBR both of my SP-1's. I'm also sending in paperwork to make an AOW Mossberg too. It's funny, my SBRs and SBS get 20x the use my MG ever did.
1/9/2014 10:53:51 PM EDT
[#12]
You could do it inside the trigger guard and no body will ever know it is there.
1/11/2014 12:48:36 PM EDT
[#13]
Would it be legal to get it engraved on the removable trigger guard?  Then if you wanted to return the rifle to it's original state you simply have to swap out the trigger guard itself?
1/11/2014 1:50:36 PM EDT
[#14]
Trigger guard is not the receiver. That's like saying, could you engrave the magazine release?

1/12/2014 10:48:21 AM EDT
[#15]
Quote History
Quoted:
Trigger guard is not the receiver. That's like saying, could you engrave the magazine release?

View Quote


The trigger guard is part of the receiver on some like Noveske Gen 2.  
1/12/2014 12:03:22 PM EDT
[#16]
Quote History
Quoted:


The trigger guard is part of the receiver on some like Noveske Gen 2.  
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Quoted:
Quoted:
Trigger guard is not the receiver. That's like saying, could you engrave the magazine release?



The trigger guard is part of the receiver on some like Noveske Gen 2.  


Yes, but he was answering the original question regarding a removable triggerguard:

Quoted:
Would it be legal to get it engraved on the removable trigger guard?  Then if you wanted to return the rifle to it's original state you simply have to swap out the trigger guard itself?

1/16/2014 6:29:28 AM EDT
[#17]
Why not leave the short barrel on your engraved lower and just engrave the other barrels you use since your friend is doing the engraving?
1/16/2014 9:07:32 PM EDT
[#18]
Quote History
Quoted:
Why not leave the short barrel on your engraved lower and just engrave the other barrels you use since your friend is doing the engraving?
View Quote


I considered that too. The only problem with that option is the way I have my other SBR uppers configured. They have a more modern look to them and they wouldn't look right on old, slab sided SP-1 lowers. This isn't exactly the way it's configured now, but you can get the idea.



But this will look right on an SP-1 lower.

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