I realize we’ve discussed SBR and SBR-related engraving requirements about 10,000 times already, but I do have some lingering questions about some of the finer points of the law, and would be interested in the SOT/dealer/manufacturer view.
My purpose here is not to challenge the well-known 27 CFR 479.102 (ATF 5300.4) requirements, so I’m not looking for someone to re-post one of the enigmatic ATF compliance/interpretation letters that show up online every now and again. Instead, my question is this: what if I wish to do a Form 1 conversion without engraving the lower?
In the case of a Magpul or other unusually valuable lower, there will surely be instances where the owner is unwilling to engrave the receiver, but would still like to add the weapon to the NFA SBR registry for use with a short-barreled upper. The law would seem to allow engraving the barrel in lieu of the receiver or frame. I do understand that every barrel used with the weapon would have to meet this requirement, but a correctly engraved 10.5" or 11.5" barrel should still conform to the letter of the law.
Now, let’s say that it is a very short barrel that is almost completely shrouded by a rail system. Would an inscription that is plainly visible through the vents/lightening cuts in the rail meet the legal requirements here, or would this likely be challenged by an examiner? Before you say it, I already know that “only an examiner could really answer the question,” and that if I asked the question 10 times to 10 different examiners, I could probably get at least three “official” rulings that contradicted each other. This is not my first ride on the NFA bus.
What I’m really after is simply an informed opinion by those actually engaged in the business, in the hopes that you may have encountered a similar situation in the past, or have other insights to pass along. In an SBR barrel engraving situation, is a good faith effort to comply with the law (i.e. correct engraving visible through rail) generally going to be ruled as sufficient, or have you encountered situations where this technique proved problematic?
Clearly, it makes the most overt sense to just engrave the receiver, but when that isn’t practical or possible, how deep into the woods is an alternate approach (barrel engraving) likely to take an NFA owner?
I’m in the process of doing a SBR & besides the name/city/state I am also adding the SN to the barrel of the lower that I am doing the Form 1 on.
The barreled upper is going to stay on the SBR registered lower.
Edit:
I’m not in the business but from my take I would think it would fly. I would be shure it is visible, unlike my Volmer MP5 which is under the stockline
Actually, the law stipulates “frame, receiver or barrel,” but I’m not altogether certain how that has been applied toward modular systems like the AR. I used to have a much better grasp on NFA law a number of years ago, but am not sure that I ever saw this question dealt with specifically.
I’ve thought of this too. I dismissed it thinking if it was good to go why wouldn’t more people do it. I would think it would be GTG with a fixed bbl weapon but not one with a a bbl so easily removed. Something like a lever action 30-30 or a Thompson.
One if my SBR’s has a Redi-Mod covering the SSN. Is that an issue? It would only take a few min to remove the unit to get to the SSN.
I always like hearing from Todd K. On issues like this.
ToddK is one of the main reasons that I posted this here, as opposed to simply sending an e-mail or PM. More to the point, the upper that is prompting the discussion is a NRW CQB (10.5") that I’d very much like to mount to a MPLA – but I’m understandably very hesitant about engraving this lower.
I would have no problem tucking some engraving on the front of the magwell on a A series lower if I was sound in the fact that the engraver I decide to roll with will do a good job.
If I get my unicorn the C doll or that damn elusive B series you can unequivocally count on it going in the grave with me or to my first male born child so I could care less about any monetary value associated with it and the engraving detriment to it.
Engraving the front of the magwell isn’t really an option on the Magpul lowers because of the machining in that area, but I do understand where you’re coming from.
To be honest, I’m unwilling to mar the receiver because I haven’t yet reached a point at which my sentimental attachment has trumped the simple pragmatism associated with owning such a steadily-appreciating asset. With prices climbing north of $3,000 for a component that does the same job no more capably than a $300 receiver, my enjoyment factor in owning such a piece isn’t exactly keeping pace.
I know DD and Noveske will take one of their regular lowers back and add it to their books as an SBR if you buy the SBR upper from them. If you could get that done you wouldn’t have to engrave your lower.
Having done that with Noveske in the past (on N4 lowers), I’m totally tracking there.
The question is: can Noveske do that with Magpul lower that was originally sourced/sold as one of their (Noveske) package rifles? In this case, who was the manufacturer in the eyes of the law: NRW or Magpul? Since I’ve no idea how any of this was entered in their books, I’ve got no idea if NRW could legally re-enter a MPLA lower on their books as a new NRW factory SBR. While this would be the best of all possible solutions, for some reason, it strikes me as something of a long shot.
I would think it would have to go back to the original manufacturer but that is just a guess. I have a regular LMT lower id like to send back. Im going to email them.
Duh,…I have stared at the magpul lowers for yrs. yet that slipped my mind about the machining up front.
My love over these lowers trumped a good point you made that I assume most owners of a single magpul lower struggle with, which is battling the ever increasing and to some ridiculous resale value of these on the peer to peer market.
Given your quite the AR connoisseur as well as a fan of both Magpul and Noveske, I would think that you would already be sold on that piece of awesomeness but there is indeed so much more AR kit that can be had for the inflated value of magpul lowers these days.
The law doesn’t make any distinction about ease or difficulty of taking the barrel out. If the correct markings are on the gun it is fine.
I see “otherwise conspicuously placed” as allowing other methods (otherwise “in another manner; differently” conspicuously placed, “obvious; readily visible or observable”) of manufacturing markings.
I would feel comfortable if someone looking for the markings could find them readily visible by inspecting the frame, receiver, and barrel.
If we make a rifle into an SBR it would need our markings as the manufacturer of the SBR.
Just to throw one final curve ball at this topic, would you view the required information appearing prominently on the upper receiver of the weapon as fundamentally in compliance with the law? We’re assuming here that the upper and barrel would always remain with the lower, andt there is no demonstrable intent to use components of the weapon with other modular assemblies.
Caveat: I acknowledge that you are neither a lawyer, nor an ATF Examiner. Just looking for an informed opinion from a reasonable man.
Well I am not a lawyer either but this just hit me like a sledge hammer!
If the short barrel is removed from the weapon (and not readily available) it is no longer an SBR. So it seems to make sense that the engraving could be on the barrel. As said before you could add the serial number of the weapon to the bbl as well.
Another solution would be to SBR all your AR’s, something I want to do just because I don’t need or want a longer bbl. I only have three guns in my collection and two are SBR’s, I know this could be costly for some.
Interested in clarification on this as I am going to SBR a SCAR not long after it arrives. With its plastic lower I would much prefer to be able to engrave the barrel.
For my AR SBR quest I have a Noveske blem lower set aside just for SBR’s so not that concerned with that one. I am trying to go the cheap route with NFA by simply adding a 10.5 barrel to an extra MRP upper I have and getting either a new barrel for the incoming SCAR or chopping the existing one from the factory.
Sadly, I don’t believe that this would actually be the case.
The weapon would not be an SBR by configuration, but in the eyes of the law, it would still be a restricted SBR, because the receiver’s serial number is what is entered on the registry. This is why I mentioned earlier that, even if you were to install a 16" barrel on an SBR that was engraved on the barrel (vice the receiver), you would still have to engrave the NFA information on your non-NFA barrel; otherwise, you would be in possession of an SBR devoid of the required engraving.
For all intents and purposes, the receiver is the weapon; we’re simply talking about ways of meeting the legal requirements without modifying or marking that particular component.
