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Engraving requirements for 07 FFLs

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  • EBR Works
    Vendor/Retailer
    • Dec 2007
    • 10492

    Engraving requirements for 07 FFLs

    I have received conflicting information from the ATF and several FFLs. Let's assume that an 07 FFL wants to do the following tasks with AR style firearms:

    1: Assemble complete firearms utilizing stripped lowers that are already engraved with the original manufacturer's markings.

    2: Assemble a firearm from a complete upper and lower from different manufacturers.

    3: Assemble a firearm from a complete upper and lower from the same manufacturer.

    4: Reassemble a complete rifle that was shipped as separated upper and lower. The FFL installs a bullet button for compliance prior to reassembly.


    In which of these scenarios does the 07 need to engrave the receiver with his markings?

    ..and yes I have read the markings scenarios that ATF published. They don't address these questions.
    Last edited by EBR Works; 05-06-2011, 8:43 PM.


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  • #2
    Table Rock Arms
    Senior Member
    • Jan 2009
    • 812

    Everyone has a different answer to those questions. I would say all of them except #4 you would have to engrave your Information. More importantly, all of them except #4 would have to have FET paid(assuming you do more than 50 per year).

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    • #3
      GunsAndAmmoGirl
      Junior Member
      • Mar 2011
      • 52

      It would be great if someone had the answers to your questions. In fact I was excited to see your post because I have the same questions myself.

      All the ATF could tell me was that it was a "gray" area and that I should add manufacturer to my current FFL. hmm... However, when I read the ATF regs about markings, I was quite confused because the lower is already stamped with the manufacturer info and serial number.

      If anyone has any info it would be greatly appreciated!!
      sigpic
      www.HighDesertGunsAndAmmo.com

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      • #4
        AJAX22
        I need a LIFE!!
        • May 2006
        • 14980

        All of them.

        Any manufacturing process performed on a firearm receiver is required to be done by an 07FFL, and each FFL must either engrave their information on the gun or obtain a variance from the BATFE exempting them from the marking requirement.

        (I actually have a letter pending with the BATFE that addresses this issue specifically, clearly, and should answer it once and for all)
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        • #5
          JeffM
          Veteran Member
          • Sep 2007
          • 4359

          Originally posted by AJAX22
          All of them.

          Any manufacturing process performed on a firearm receiver is required to be done by an 07FFL, and each FFL must either engrave their information on the gun or obtain a variance from the BATFE exempting them from the marking requirement.

          (I actually have a letter pending with the BATFE that addresses this issue specifically, clearly, and should answer it once and for all)
          This.

          Unless #4 is sold as a complete rifle from the manufacturer, but simply broken down for shipping. It would already be an FET-paid complete rifle.

          This is why you cannot have a simple stripped receiver and all the parts for a complete gun on the same order. Try to order a complete AR kit from a place like Delton with a receiver on on the same order. They won't do it because it would be considered a complete rifle (in what's know as "knock-down" configuration) requiring FET to be paid and subjecting it to the BATF marking requirements.

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          • #6
            AJAX22
            I need a LIFE!!
            • May 2006
            • 14980

            Originally posted by JeffM
            This.

            Unless #4 is sold as a complete rifle from the manufacturer, but simply broken down for shipping. It would already be an FET-paid complete rifle.

            This is why you cannot have a simple stripped receiver and all the parts for a complete gun on the same order. Try to order a complete AR kit from a place like Delton with a receiver on on the same order. They won't do it because it would be considered a complete rifle (in what's know as "knock-down" configuration) requiring FET to be paid and subjecting it to the BATF marking requirements.
            Ahh yes, JeffM is correct on #4, I made the assumption that FET had not been paid (i.e. someone had a complete upper and lower shipped to the FFL on their behalf but not at the same time and not from one source)
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            • #7
              EBR Works
              Vendor/Retailer
              • Dec 2007
              • 10492

              OK, thanks for the clarification. Anybody have recommendations for reasonable engraving services?


              Check out our e-commerce site here:

              www.ebrworks.com

              Serving you from Prescott, AZ

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              • #8
                AJAX22
                I need a LIFE!!
                • May 2006
                • 14980

                I believe the FFL has to do it on the licenced premises or they have to send it to another FFL 07 who can get a waiver to mark it for them (cheaper to just have an 07ffl make the lowers on a variance from the get-go)

                A manual panograph setup should run somewhere between 400 and 1200 depending on the accessories, fonts, spares and accessories that come with it.
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                • #9
                  EBR Works
                  Vendor/Retailer
                  • Dec 2007
                  • 10492

                  Any links to suppliers of pantograph machines in that price range? Most everything I found was several thousands of dollars.


                  Check out our e-commerce site here:

                  www.ebrworks.com

                  Serving you from Prescott, AZ

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                  • #10
                    AJAX22
                    I need a LIFE!!
                    • May 2006
                    • 14980

                    Originally posted by impactco
                    Any links to suppliers of pantograph machines in that price range? Most everything I found was several thousands of dollars.
                    Ebay and craigslist.... buy local if you can, shipping is a PITA

                    I helped one of our friendly CA MFG's source one a year or so ago.

                    just a fyi, don't buy one thats a 'project' parts are stupid expensive.
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                    • #11
                      EBR Works
                      Vendor/Retailer
                      • Dec 2007
                      • 10492

                      Hmm, sounds like a grand science experiment with used gear. I wonder if any of the available $2k-$3k laser engravers are sufficient to meet ATF requirements. I'll need to do some research....


                      Check out our e-commerce site here:

                      www.ebrworks.com

                      Serving you from Prescott, AZ

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                      • #12
                        Table Rock Arms
                        Senior Member
                        • Jan 2009
                        • 812

                        Originally posted by impactco
                        OK, thanks for the clarification. Anybody have recommendations for reasonable engraving services?
                        If your doing lowers, I would consider having your own lowers made. By the time you buy lowers and have them engraved and refinished, you will be in it for more than if you just had the lowers machined with your info. There are minimum orders of course, so you will have to pony up initially. But if your building rifles it would be nice to just have your own lowers vs having someone's lower with your info also engraved on it.

                        Ryan

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                        • #13
                          SJgunguy24
                          I need a LIFE!!
                          • May 2008
                          • 14849

                          You could buy a small cnc mini mill and run a program for engraving. I talked to a few laser engravers in the San Jose area and to get .030" deep takes some power, more then most of the trophy or hobby machines can do.
                          IIRC you can take your receivers to a place and stay until the work is done.
                          There are 3 kinds of people in this world.
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                          The smart, learn from their own mistakes.
                          The others, well......they just never learn.

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                          • #14
                            Table Rock Arms
                            Senior Member
                            • Jan 2009
                            • 812

                            Originally posted by SJgunguy24
                            You could buy a small cnc mini mill and run a program for engraving. I talked to a few laser engravers in the San Jose area and to get .030" deep takes some power, more then most of the trophy or hobby machines can do.
                            IIRC you can take your receivers to a place and stay until the work is done.
                            This is more than likely your best bet for an engraver. You can get a TAIG or Sherline CNC mill for less than you can get the laser engraver for. The nice thing is you can do other things with it besides just engrave. Depending on your current knowledge of CNC, there could be a bit of a learning curve however.

                            I am sure that .030 is a typo, but the ATF marking requirement is .003 in depth. I was told when I got my FFL however that they are looking at changing it to .005 so I might as well set up my tooling for .005, That could be complete BS, but that is what I was told.

                            Ryan

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                            • #15
                              GoingQuiet
                              Vendor/Retailer
                              • Oct 2010
                              • 2731

                              Originally posted by impactco
                              Hmm, sounds like a grand science experiment with used gear. I wonder if any of the available $2k-$3k laser engravers are sufficient to meet ATF requirements. I'll need to do some research....
                              Keep in mind - most laser engravers won't engrave anything. They just strip finish.
                              GoingQuiet.com, 07/02 FFL
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