No need for engraving SBR lower?

General Firearms NFA
1

So I want to register a Noveske lower that I already own. I called my local class 3 dealer since I have not dealt with the NFA before. I asked if there are any local engravers that he would recommend to me. He then told me that there is no need to engrave the lower and he has done this multiple times for multiple customers with no problems. He also said that there is no such requirement written into the law and that the engraving requirement is just a myth similar to the “three step law.”

Is this accurate at all? I have always been under the impression that if it is not a factory SBR, I have to get the lower engraved so this sounded very strange to me…

I have read scottryan’s sticky a few times and see that it does say to engrave the lower. I also searched for other threads and did not find anything.

P.S.: Can anyone refer me a lawyer to write a NFA trust in the Palm Beach/Broward, FL area?

Thanks for any help.

2

https://www.m4carbine.net/showthread.php?t=139940&highlight=engraving+SBR My dealer told me same thing about my SBRs. Did anyway, I don’t mind engraving my name on my guns though so was mute point for me…

3

He is going to get people sent to prison. I would be looking for a new firearms dealer to work with…

ATF 5300.4 in 27 CFR 479.102 (page 92) describes what is necessary to engrave on a SBR or SBS when one is manufacturing. This is not necessary if you purchase one that is already manufactured as it will have been done for you.

  1. On the Frame or Receiver the Serial number;
  2. on the frame, receiver, or barrel the following additional information;
    A)The model;
    B)The caliber or gage;
    C)Your name or name of the Trust in the case of a Trust (no abbreviations are permitted for the Trust name);
    D)The city and state (you can abbreviate the state with the official 2 digit state code)
    The above mentioned information must be engraved, casted, stamped (impressing) or otherwise conspicuously placed or caused to be engraved, cast, stamped (impressed) or placed to a minimum depth of .003 inch and in a print size of the Serial number shall be no smaller than 1/16 inch.
4

Thank you. I dont know how i missed that thread. I dont have a problem having my lower engraved either, but I would like to find someone local…hopefully…

Thanks. I thought I was right. Just to clarify, SBRing my lower and building an upper for it is considered manufacturing, correct?

5

That is correct.

6

The reason your dealer has had “no problem” is that it would be extraordinarily rare that an ATF agent would ever be out anywhere on “NFA patrol” and actually enforce that law. But the NFA is clear, along with formal opinions from various NFA interim directors, you have to engrave your lower.

To nit pick, putting a barrel less than 16 inches, or upper with attached barrel less than 16 inches is manufacturing an SBR. The ATF does make kind of a soft distinction in the language between “manufacturer” and “maker”, with manufacturer being the company that originally made the lower (ie. Noveske) and the maker being the person who put the short barrel on it (ie. you). View the engraving rules as meaning that both Noveske and you have to engrave. They don’t make you put on a serial number…they let you use the one that Noveske already engraved.

7

Had you taken delivery of the lower already registered as an SBR component from Noveske, then no engraving would be required.

Since you are the one “making” the SBR in this case from a non-NFA lower, engraving is indeed required.

AC

8

While on the subject, is there a time limit to engrave NFA item before out of compliance?

9

Compliance is based upon configuration, not time.

Got an NFA-length upper on it? It needs to be marked.

Got a non-NFA-length upper on it? Then it is only papered as an SBR, but not legally in a configuration that requires engraving.

Most guys just send their lowers off for engraving when they submit their NFA paperwork to avoid any potential issues later on.

AC

10

Thanks, have been asked this by shooting buddies curios about NFA process/rules/etc… Have read scottryan’s rules (rule #11 as this applies) and passed info along/sent link. But when I can’t answer a question, the eluded answer annoys me.