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Posted: 9/20/2017 12:55:02 PM EDT
[#1]
Yes. If you manufacture a firearm, it must be marked.
However, you can "adopt" certain markings - caliber, model, serial number (as long as it's not something you've used before). Most cases you only need to add Manufacturer and City/State. |
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Posted: 9/20/2017 1:15:31 PM EDT
[#2]
Could the original manufacturer engrave them for you prior to delivery, or must you engrave them after they have been added to your bound book? I don't see how that would be different in the end than sending it out for engraving after the finished receiver was received.
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Posted: 9/20/2017 1:55:43 PM EDT
[#3]
Quote HistoryQuoted:
Could the original manufacturer engrave them for you prior to delivery, or must you engrave them after they have been added to your bound book? I don't see how that would be different in the end than sending it out for engraving after the finished receiver was received. That's how Aero Precision and other manufacturers will do runs for Spikes, Palmetto, etc. |
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Posted: 9/20/2017 2:21:00 PM EDT
[#4]
<50 per year still exempt from FAET?
Edit: yes https://www.ttb.gov/firearms/faet-faqs.shtml Could the 07 FFL receive a variance exempting them from the manufacturer and city/state engraving requirement? Has this happened (requested/received)? |
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Posted: 9/20/2017 2:52:23 PM EDT
[#5]
I have never engraved any of the guns I have made, as they were not made to sell, they are simply personal use guns, if I choose to sell one or give one away I have to engrave my information and a serial number on it. I was told this is legal by a BATE supervisor.
If you are building with the intent to sell or give away, they have to be engraved. There is that dirty little word again "Intent" and unfortunately, you don't decide what your intent is, they do. |
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Posted: 9/20/2017 5:54:34 PM EDT
[#6]
Quote HistoryQuote HistoryCould the 07 FFL receive a variance exempting them from the manufacturer and city/state engraving requirement? Has this happened (requested/received)? |
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Posted: 9/20/2017 6:11:14 PM EDT
[#7]
Quote HistoryQuoted:
No such exemption in the law. |
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Posted: 9/20/2017 7:54:03 PM EDT
[#8]
Quote HistoryQuoted:
There is for DDs at least, if such exception is approved by the director of ATF. |
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Posted: 9/20/2017 7:56:53 PM EDT
[#9]
Quote HistoryQuoted:
Don't forget ITAR at $2250 each year. No such exemption in the law. |
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Posted: 9/20/2017 8:07:00 PM EDT
[#10]
Quote HistoryQuoted:
So you need ITAR to assemble an AR kit for domestic sale? If you are doing ANY machining operation then yes. Domestic sales are treated exactly the same is exports. |
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Posted: 9/20/2017 9:54:24 PM EDT
[#11]
Quote HistoryQuoted:
DDTC says no......if all you are doing is assembly of parts manufactured by others. If you are doing ANY machining operation then yes. Domestic sales are treated exactly the same is exports. Quote HistoryQuoted:
DDTC says no......if all you are doing is assembly of parts manufactured by others. If you are doing ANY machining operation then yes. Domestic sales are treated exactly the same is exports. http://www.dunlap-stone.edu/itar-compliance-and-itar-certified/ Here is an line from the page I have linked: For a company involved in the manufacture, sale or distribution of goods or services covered under the United States Munitions List (USML) |
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Posted: 9/21/2017 8:48:00 AM EDT
[#12]
Quote HistoryQuoted:
Nope, if you are assembling parts that are covered by ITAR, then you also must be ITAR compliant. DDTC has issued other guidance to FFL's with a manufacturer's license. In their world "assembly" <> "manufacturing", though in the ATF's world it is because of the collection of FAET; remember the ATF is at its base a tax collection agency and that drives many of their regulatory processes. Once a manufacturer starts mllling or drilling then ITAR registration is required. |
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Posted: 9/21/2017 12:30:46 PM EDT
[#13]
Quote HistoryQuoted:
DDTC has issued other guidance to FFL's with a manufacturer's license. In their world "assembly" <> "manufacturing", though in the ATF's world it is because of the collection of FAET; remember the ATF is at its base a tax collection agency and that drives many of their regulatory processes. Once a manufacturer starts mllling or drilling then ITAR registration is required. What ATF considers as a manufacturing activity is completely different than what DDTC considers as manufacturing. |
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Posted: 9/21/2017 12:35:19 PM EDT
[#14]
Quote HistoryQuoted:
Nope, if you are assembling parts that are covered by ITAR, then you also must be ITAR compliant. http://www.dunlap-stone.edu/itar-compliance-and-itar-certified/ Here is an line from the page I have linked: Quote HistoryQuoted:
Quoted:
DDTC says no......if all you are doing is assembly of parts manufactured by others. If you are doing ANY machining operation then yes. Domestic sales are treated exactly the same is exports. http://www.dunlap-stone.edu/itar-compliance-and-itar-certified/ Here is an line from the page I have linked: For a company involved in the manufacture, sale or distribution of goods or services covered under the United States Munitions List (USML) Instead read the stuff here:Dept of State DDTC And most importantly what Adam Kraut wrote here: Prince Law Firm article |
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Posted: 9/21/2017 12:58:58 PM EDT
[#15]
Quote HistoryQuoted:
That link is rife with misinformation. The most glaring is the last quote......it's flat out wrong. Instead read the stuff here:Dept of State DDTC And most importantly what Adam Kraut wrote here: Prince Law Firm article |
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Posted: 9/21/2017 5:12:20 PM EDT
[#16]
Almost everything written about ITAR wrt firearms over the years has been wrong, except of course for what I wrote having worked ITAR as a fed I had an inside track). hence the FAQs issues by DDTC to clear things up, repeating of course what I wrote.
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Posted: 10/1/2017 8:39:17 PM EDT
[#17]
Interesting discussion. An FFL 07 that assembles AR15 lower halves a from parts kits needs to engrave their own info? Assume the receiver is already marked by the manufacturer of the receiver. Eg Aero Precision.
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Posted: 10/1/2017 8:45:49 PM EDT
[#18]
Quote HistoryQuoted:
Interesting discussion. An FFL 07 that assembles AR15 lower halves a from parts kits needs to engrave their own info? Assume the receiver is already marked by the manufacturer of the receiver. Eg Aero Precision. Quote HistoryQuoted:
Interesting discussion. An FFL 07 that assembles AR15 lower halves a from parts kits needs to engrave their own info? Assume the receiver is already marked by the manufacturer of the receiver. Eg Aero Precision. Yes. I was just reading back through the thread and saw this: Quoted:I have never engraved any of the guns I have made, as they were not made to sell, they are simply personal use guns, if I choose to sell one or give one away I have to engrave my information and a serial number on it. I was told this is legal by a BATE supervisor. There is no federal requirement for a non-licensee to engrave make/model/serial # on a Title I firearm; it can be sold sterile. Some states have their own laws regarding such. ATF strongly suggests that it be done but it's not a federal law that it's required; 27 CFR § 478.92 only applies to licensed manufacturers and importers. |
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