Engraving ambiguity for Form1

[Abbey]

I've always been of the opinion that it's not that big of a deal to engrave a receiver so just do it to eliminate the risk that it gets challenged by an overzealous cop or AFT agent. (Even though I have literally never been challenged or asked for paperwork anywhere ever.) I felt that the original intent of engraving was for "real" manufacturers, but the letter of the law seemed clear enough that I was "manufacturing" a Title II gun out of a Title I gun. It's stupid, but whatever, I'll play along.

But since I've been having trouble finding time on Wright Armory's schedule to engrave a couple recent eForm 1s (my first e-Forms, through SilencerShop) and realized that my approved form 1s have a blank box h "Additional Description". So basically there is nothing on my approved form indicating my marking. So from my perspective, my Form1 is indistinguishable from the firearm description on a factory SBR form 4.

Is this normal? In the pre-e-file days I always had my marking in box h. Did the engraving requirement get relaxed after all of the brace nonsense last year or something?

[any4xx]

I’m not sure I have an answer, but I just did my first SBR Form-1 about a week ago. I sent Silencer Shop the picture of my lower that I’ve had about ten years. They filled out the Form-1 then emailed me a few days later to certify it with ATF. Nothing was added. Just my branded and serialized lower as it left Franklin Armory several years ago. I certified it and got my approval from ATF 38 hours & 28 minutes later. Nothing was ever said about my having to add any markings.

I’d “guess” that if you were building your own unserialized lower you’d have to add engravings listing yourself as the manufacturer and adding a serial number???

[QuietM4]

It's not ambiguous at all. ATF Form 1 is titled 'Application to Make and Register a Firearm'. YOU are the manufacturer of the new NFA item, and as such are legally required to engrave your manufacturing information on the firearm receiver. It's pretty simple.

Your name (or the legal entity that registered the firearm) that is located in Box 3b, will dictate the required manufacturers markings, e.g "Joe Blow, Phoenix AZ".
Box 4h is normally left blank. You can also add additional calibers and barrel length configurations here as well, or any other manufacturing markings that are engraved on the firearms (e.g. an old worn out serial number on an imported machine gun, etc)

Wright Armory only sets appointments for NFA engraving on Monday afternoons...they have done many NFA laser markings for me. If you don't want to sit and wait on a Monday afternoon, just drop off the receiver with a copy of your approved Form 1, and they will engrave it the following Monday. Then pick it up as your schedule permits.

[QuietM4]

I’m not sure I have an answer, but I just did my first SBR Form-1 about a week ago. I sent Silencer Shop the picture of my lower that I’ve had about ten years. They filled out the Form-1 then emailed me a few days later to certify it with ATF. Nothing was added. Just my branded and serialized lower as it left Franklin Armory several years ago. I certified it and got my approval from ATF 38 hours & 28 minutes later. Nothing was ever said about my having to add any markings.

I’d “guess” that if you were building your own unserialized lower you’d have to add engravings listing yourself as the manufacturer and adding a serial number???

You are absolutely legally required to engrave the new manufacturer information on the receiver (e.g. your name and location...whatever is listed in Box 3b of your approved Form 1).

[any4xx]

Hmmmm…. Guess I’ve got some engraving to do…

[Abbey]

My recent experience is identical to yours, although my approvals were a few days, not minutes...

This is different from completely manufacturing from an unmarked 80% lower or whatever, where you'd have to put your name/marking in box 4a . In the paper Form1 days, you'd put your marking in box 4h, then were expected to mark them accordingly once your forms came back. And ATF would change their mind about where you could mark them, causing millions of internet threads. e.g., people used to mark under the grip on an AR lower or on the rear stock tang of an HK, but then there was a decree that markings needing to be in a visible location.

But its odd to me that they are now approving forms with no mention of the additional marking and an empty box H. Maybe I'm just hopeful, but it kind of feels like even ATF realizes that the markings were particularly stupid and all they care about is that they have a way to ID & track the gun (which the original manufacturer markings and serial number do).

[Abbey]

You are absolutely legally required to engrave the new manufacturer information on the receiver (e.g. your name and location...whatever is listed in Box 3a of your approved Form 1).

On my recently approved Form1s, box 3a is blank. 3b, d, e, f have my personal info.
Boxes 4a, d, g have the original manufacturer name, model, serial
box 4h is empty

[any4xx]

Ugh…. Guess I need to read some more before I start engraving. Luckily I’ve got a neighbor that can laser-engrave and mill metal so if I do need to do it I can have him knock it out for me in just a few minutes.

[QuietM4]

Ugh…. Guess I need to read some more before I start engraving. Luckily I’ve got a neighbor that can laser-engrave and mill metal so if I do need to do it I can have him knock it out for me in just a few minutes.

It has to be engraved to a certain character height and depth, legally. ATF has strict requirements for firearm markings.

[QuietM4]

You are absolutely legally required to engrave the new manufacturer information on the receiver (e.g. your name and location...whatever is listed in Box 3a of your approved Form 1).

On my recently approved Form1s, box 3a is blank. 3b, d, e, f have my personal info.
Boxes 4a, d, g have the original manufacturer name, model, serial
box 4h is empty

Box 3b will tell you what needs to be engraved. Example; Joe Blow, Phoenix AZ.

[Abbey]

I haven't collected any stamps for awhile. Guess I thought "Joe Blow, Phoenix AZ" was always in 4h in the past.

At any rate, guess I'll have to drop off my stuff at Wright. My schedule and their availability have just not been aligned. Every time I've had time on a Monday & called they said they were already booked up and to try again another week.

[Doc]

I haven't collected any stamps for awhile. Guess I thought "Joe Blow, Phoenix AZ" was always in 4h in the past.

At any rate, guess I'll have to drop off my stuff at Wright. My schedule and their availability have just not been aligned. Every time I've had time on a Monday & called they said they were already booked up and to try again another week.

I’ve got a buddy who does engraving. He’s near I-17/Greenway. Let me know if you want his contact info.

[YNOTAZ]

Just an FYI, up until recently Local LEOs and MCSO were told that and SBR or SBS could be field verified by looking for the engraving. It is a reasonable assumption that somebody that went through the trouble to get their firearm engraved had a stamp at home or online.

The only thing that changed are the freebie Form 1s for pistol braces. They don't require engraving, so the theory of an engraved gun implies a stamp, goes out the window.

[any4xx]

Hmmmm…. I’m even more confused now. My box 3b is my full legal name and complete address to include zip code and “UNITED STATES.”

[any4xx]

I just did some searching and Silencer Central has a FAQ page on what is required for an SBR. It gives all of the spec’s and requirements. It looks like since I’m using an existing serialized lower I just need to add my name and city/state.

https://www.silencercentral.com/blog/ev ... now-about/