Assembling complete AR uppers & lowers is manufacturing/secondary markings required??

[EBR Works]

In conversation with the IOI with whom I will do my initial interview for an 07 later this week I mentioned that I intended to buy complete uppers and lowers and assemble them for sale. She stated that as an FFL it was mandatory that I mark these firearms with my own markings. This was very surprising to me since I cannot see how assembling a completed upper and lower would necessitate secondary markings. Any thoughts on this?

[bjl333]

Really!! I must've broken the law many times ...

[jtmkinsd]

You would be completing the build of a functional firearm, then selling it. Unfortunately, that simple step is manufacturing I believe. It's the reason I can receive lowers without a bullet button installed, because even though the upper and lower are in the same box, it's not a complete rifle till I put them together. If I put them together I have "manufactured" an illegal assault weapon. Technically, if someone buys all the parts to a rifle and has them shipped to me, I can't assemble them until they have done their DROS, waited their 10 days, picked up their parts, and then give them back to me as a repair job.

[Table Rock Arms]

You would also be required to pay FET of 11% if you do more than 50 in a year.

[bohoki]

i guess you are "making" a rifle

an ffl told me that years ago
everyday joes are exempt because we are allowed to make a firearm for our own personal usage

it does sound a bit odd to say you manufactured the rifle being it has a manufacturer and serial on it but legally i guess its true

[EBR Works]

My puzzlement is in the requirement to add markings in this scenario even though the receiver already has the original manufacturer markings. We're talking about mating a complete upper and lower, not assembling a firearm from parts.

[FNH5-7]

In conversation with the IOI with whom I will do my initial interview for an 07 later this week I mentioned that I intended to buy complete uppers and lowers and assemble them for sale. She stated that as an FFL it was mandatory that I mark these firearms with my own markings. This was very surprising to me since I cannot see how assembling a completed upper and lower is manufacturing. Any thoughts on this?

My thoughts exactly, unfortunately this is the law and this is what I've been told by many FFL's when I was trying to have an AR Pistol built.