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What is the Engraving Requirement for NFA firearms?

You cannot trust everything you read on the Internet about the engraving requirement for NFA firearms. Some forum discussions have been telling people to engrave all firearms assigned to or bought by their NFA gun trust. This is completely incorrect. Only manufacturers, importers (into the U.S.), and maker of firearms are required to engrave firearms. See 27 C.F.R. § 479.102. Buyers of already-manufactured firearms, regardless of whether they are individuals or entities (such as NFA gun trusts), are not required to engrave firearms.

If, for example, an individual or an NFA gun trust wants to build a short-barreled rifle (“SBR”), the individual or NFA gun trust must file an Application to Make and Register a Firearm (ATF Form 1) and receive permission from the ATF to make the SBR. The approved ATF Form 1 (“ATF tax stamp”) is the permission from the ATF to make the SBR. See 27 C.F.R. § 479.64 (“The maker of the firearm shall not, under any circumstances, make the firearm until the application, satisfactorily executed, has been forwarded to the Director and has been approved and returned by the Director with the National Firearms Act stamp affixed.”). The tax stamp includes the make, model, and serial number of the lower receiver, which has already been engraved by the manufacturer. See 27 C.F.R. § 479.62. The ATF tax stamp also includes the barrel length (without detachable flash hider) of the SBR, the total length of the SBR (adjustable stock fully-extended), and the caliber or gauge of the SBR (only one may be selected). See id. When the NFA gun trust is the maker, the SBR must be marked conspicuously on the frame, receiver, or barrel with the name of the trust and the city and state (two-letter postal abbreviation acceptable) where the SBR is made. See 27 C.F.R. § 479.102(a)(2). If an individual is the maker, the individual’s name and the city and state is required to be marked on the SBR. Id.

Similarly, if an individual or NFA gun trust wants to build a suppressor or silencer, the same engraving requirement applies. The individual or NFA gun trust must file an Application to Make and Register a Firearm (ATF Form 1) and receive permission from the ATF to make the suppressor. The approved ATF Form 1 (“ATF tax stamp”) is the permission from the ATF to make the suppressor. In addition to engraving the name of the individual or trust and the city and state, the maker of a suppressor will also engrave the serial number of that weapon. On the ATF Form 1, the maker of the suppressor tells the ATF what it wants the serial number of this suppressor to be, such as BOND007 or 12345. When the ATF tax stamp is issued, then it is time to engrave the weapon exactly as stated on the ATF tax stamp.

The details of how to engrave are stated in the Code of Federal Regulations (“CFRs”). See 27 C.F.R. § 479.102. We recommend using an engraver familiar with the engraving requirement for firearms.

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