Hello Legal Eagles

I was reading the ATF circular about the engraving requirements for NFA manufactueres.
Text of ATF circular.



There is a thread about it in the M-16 Forum Thread on SBR engraving


Basically there is a guy who wrote a letter to the NFA Tech Branch and they said his non NFA HK94 and non NFA SP89 did not need to be engraved with any additional information after they have been converted to short barreled rifles.

Uzi Talk Thread with letter from Tech Branch

To me this makes perfect sense. And here is what I think is there reasoning behind it.

§ 179.102, the section that refers to NFA firearms does not mention SBR's or SBS, only machine guns, destructive devices, and silencers. All of which would require that the indiviudal manufacture the receiver themselfs, purchase them from a manufacturer, or fundamentally modify the receiver (in the case of the machine gun) to create. It does not list Short Barreled Rifles nor Short Barreled Shotguns nor AOWS, all of which can be created from an existing receiver (completed weapon).

Section (e) states that any receiver that is not shipped, sold or other wise transfered as a complete weapon should be marked. It does not say firearm which is clearly defined within the NFA regulations, but weapon. A complete rifle is a weapon, it may not be a "firearm" per NFA but it is a weapon, and as such should not need to be remarked with any additional data per 27 CFR 179.

So reading the complete 27 CFR 179.102 what do you think?