80% lowers MERGED THREADS - please ask in here, not a new thread

[oleg114208]

is there any requirement for serial besides .003 depth like minimal characters and letters and numbers?

[familyfarm]

ATF has published guidance stating if you make your own firearm for yourself, that's fine. If you later decide to sell it, that's OK, but it has to first be marked in accordance with ATF regulations as to size, information, depth of markings, etc. So in practice, there are people in the USA that assign markings "pursuant" to ATF regulation (27 CFR 478.92) and , who are NOT holders of ANY FFL.

Which means a non-licensee can assign the requisite markings "pursuant" to 18 USC 921, via the requirements in the Code of Federal Regulations, 27 CFR 478.92. So...ATF says it can be done. CA law says you're OK if you have information marked pursuant to Federal law.

Thanks for the response on this complex topic. Indeed a Gordian knot. I agree with you that Federal Law allows us to mark these and be OK and that previous CA law embraced that. However the new PC only gives us two valid ways to serialize guns - Either through Section 23910 or through Chapter 44. Neither gives an unlicensed manufacturer any help here. Everything you say is true wrt to Federal law but how do we link it to one of these two sections so we can be exempt from the requirement for a CA DOJ-assigned serial?? I have searched both for an help but not found it.

And for the guy looking for the ATF marking standards I am sure you can google those - From memory - Need your full name (maker) Caliber,city of manufacture, model, Serial number that ends in a number. There is a minimum size and depth requirement too. Enjoy

[edwardm]

Thanks for the response on this complex topic. Indeed a Gordian knot. I agree with you that Federal Law allows us to mark these and be OK and that previous CA law embraced that. However the new PC only gives us two valid ways to serialize guns - Either through Section 23910 or through Chapter 44. Neither gives an unlicensed manufacturer any help here. Everything you say is true wrt to Federal law but how do we link it to one of these two sections so we can be exempt from the requirement for a CA DOJ-assigned serial?? I have searched both for an help but not found it.

How do you link it? ATF tells non-licensees to mark in accordance to Federal regulation to sell a self-built firearm. I don't see where there is anything to link. Or rather maybe I don't see what link is missing. Draw me a picture and use small words. I won't mind. I'm dense sometimes.

Mind you though, I am talking about *now*, since AB-857 is not effective until 2018. After the effective date, the ATF NON-licensee compliance argument evaporates.

My position is that self-marking to ATF requirements should be satisfactory prior to the effective date of AB-857. Afterwards, I see now way around either an 07 FFL being involved or DOJ being involved.

Assuming I'm wrong on all accounts, that still leaves 23910. That allows for voluntary registration, using your own markings, including your own serial #. That, if used now, let's you avoid the DOJ number assignment (you get to pick your own) and the 10-day turnaround between issuance and verification of marking compliance.

There is another option, which ethically I can't tell a client to follow, but which will be my likely course of action, personally...

The State can pound sand and catch me if they can. I've had enough, and I'm not giving any more ground.



Sent from my iPhone using Tapatalk

[familyfarm]

How do you link it? ATF tells non-licensees to mark in accordance to Federal regulation to sell a self-built firearm. I don't see where there is anything to link. Or rather maybe I don't see what link is missing. Draw me a picture and use small words. I won't mind. I'm dense sometimes.

Mind you though, I am talking about *now*, since AB-857 is not effective until 2018. After the effective date, the ATF NON-licensee compliance argument evaporates.

My position is that self-marking to ATF requirements should be satisfactory prior to the effective date of AB-857. Afterwards, I see now way around either an 07 FFL being involved or DOJ being involved.

Assuming I'm wrong on all accounts, that still leaves 23910. That allows for voluntary registration, using your own markings, including your own serial #. That, if used now, let's you avoid the DOJ number assignment (you get to pick your own) and the 10-day turnaround between issuance and verification of marking compliance.

Aha! Now I understand. You are talking about today not what happens on 7/1/2018. We both seem to agree that in order to comply with 857 after that date, we cannot rely on having marked to ATF standards before that date. We would need to VolReg our serials before. Either that or take an "alternate interpretation." I have been confused with a bunch of CG folks saying that engraving to ATF standards was sufficient to satisfy the 857 regs and I was trying to understand why they thought that. In order to comply with those regs you need to invoke one of the 2 exemptions (23910 or Chapter 44) and I have found no comfort there so far!

[edwardm]

Aha! Now I understand. You are talking about today not what happens on 7/1/2018. We both seem to agree that in order to comply with 857 after that date, we cannot rely on having marked to ATF standards before that date. We would need to VolReg our serials before. Either that or take an "alternate interpretation." I have been confused with a bunch of CG folks saying that engraving to ATF standards was sufficient to satisfy the 857 regs and I was trying to understand why they thought that. In order to comply with those regs you need to invoke one of the 2 exemptions (23910 or Chapter 44) and I have found no comfort there so far!

I think it comes down to comfort level and risk tolerance. The interpretations are many, some more strained than others, I admit.

I just really tire of playing California Games For California Prizes.

BTW like the avatar - someone about a mile from me has that on the side of his big jacked up truck and I love seeing it. Completely out of place around here in Libtardland, but it's one of the few things that gives me hope. That, and whoever goes to my gym with the SUV sporting a big NRA sticker (another brave soul). Lol.

[basalt]

Aha! Now I understand. You are talking about today not what happens on 7/1/2018. We both seem to agree that in order to comply with 857 after that date, we cannot rely on having marked to ATF standards before that date. We would need to VolReg our serials before. Either that or take an "alternate interpretation." I have been confused with a bunch of CG folks saying that engraving to ATF standards was sufficient to satisfy the 857 regs and I was trying to understand why they thought that. In order to comply with those regs you need to invoke one of the 2 exemptions (23910 or Chapter 44) and I have found no comfort there so far!

You do realize Chapter 44 IS to ATF standards and therefore it is only AFTER 7/1/2018 that marking to those standards then and in the future does not meet the requirements - just like you have to have built the AW prior to 1/1/17 to RAW it? If you own, posses, and have marked to ATF/CH. 44 standards prior to 7/1/2018 you have met the requirements. But after that date you cannot THEN mark according to ATF and meet the requirements.

Proving that is was or was not done prior, well that's another issue just like everything else and who will bear the burden?

[WatchMan]

Thanks for the response on this complex topic. Indeed a Gordian knot. I agree with you that Federal Law allows us to mark these and be OK and that previous CA law embraced that. However the new PC only gives us two valid ways to serialize guns - Either through Section 23910 or through Chapter 44. Neither gives an unlicensed manufacturer any help here. Everything you say is true wrt to Federal law but how do we link it to one of these two sections so we can be exempt from the requirement for a CA DOJ-assigned serial?? I have searched both for an help but not found it.

And for the guy looking for the ATF marking standards I am sure you can google those - From memory - Need your full name (maker) Caliber,city of manufacture, model, Serial number that ends in a number. There is a minimum size and depth requirement too. Enjoy

Where is the requirement "serial number must end in a number" coming from? Many have not heard of this, although this is not the first time I have seen this on this board.

[VaderSpade]

Where is the requirement "serial number must end in a number" coming from? Many have not heard of this, although this is not the first time I have seen this on this board.

I was told this by Tactical Machining, and a few other small manufactures that I engrave for.

[WatchMan]

I was told this by Tactical Machining, and a few other small manufactures that I engrave for.

I think this is worth looking into because I cannot find it anywhere (except on this board). Furthermore, a very prominent company that manufactures 80% lowers and does engraving is also stating they have never heard of it.

[VaderSpade]

Knock yourself out.
Major Manufactures have posted on these boards that serial numbers must end in a number. You can search for those but I don't think anything short of a determination letter (in writing) from the DOJ will satisfy you.
We all know phone calls to the ATF or DOJ mean NOTHING!

[WatchMan]

Knock yourself out.
Major Manufactures have posted on these boards that serial numbers must end in a number. You can search for those but I don't think anything short of a determination letter (in writing) from the DOJ will satisfy you.
We all know phone calls to the ATF or DOJ mean NOTHING!

So there are specific guidelines from the ATF on depth of engraving, the information that needs to be present (name, city, state), but nowhere can anyone find where there is a statement (from ATF) about what the serial number shall or shall not contain? This is coming from companies?

I am not trying to be argumentative. It just seems that next to the other very specific guidelines, this would be easy to find.

[VaderSpade]

The following post was posted by a company that makes lowers for 50+ manufactures.

Manufacturer = legal name, name on your CDL, I would not abbreviate it.
city= city it's made in
state= state it's made in
model= whatever you want
caliber= whatever you want
s/n = whatever you want but ending in a number, 1/16" in size

all has to be legible and visible and at LEAST .003" below coating. So it needs to be on the outside of the receiver, legible so make it legible, make is at least .010" in my experience and all of it 1/16" tall.

Just look at any other lower ever made by a manufacture to get an idea.

.

I have seen this in many post over the years, and told this by every 007 that I have engraved for.

[VaderSpade]

I am not trying to be argumentative. It just seems that next to the other very specific guidelines, this would be easy to find.

I have an idea, EVERYONE check your store bought lowers (or ANY guns) and find even ONE that the serial number does NOT end in a number!

[basalt]

I have an idea, EVERYONE check your store bought lowers (or ANY guns) and find even ONE that the serial number does NOT end in a number!

Not trying to argue, but just because all companies use a numeric (ending) serialization schema doesn't mean it is required. As soon as you make more than one, ending in a number makes it easier to track and organize.

Just sayin.

[VaderSpade]

Not trying to argue, but just because all companies use a numeric (ending) serialization schema doesn't mean it is required.

Except NO ONE seems to believe that EVERY Manufacture I have ever talked to about the subject says that it IS REQUIRED!!!!!!!!!!!!

I engrave lowers for several small 007s.

But hey maybe that rule is just for manufactures and the DOJ will be happy to register your lower that has the serial F%&k the DOJ??? How hard is it to add a -01 after the F%&k the DOJ????