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No more engraving? And benelli aftermarket bbls


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Unfortunately, I have bad news for you.... your FFL/SOT is incorrect regarding  the Form 1 engraving requirements.

This is a direct link to the BATFE CFR (Code of Federal Regulations) regarding the identification of firearms.

https://regulations.atf.gov/479-102/2023-01001#479-102

§ 479.102 Identification of firearms.

A. Identification required. Except as otherwise provided in this section, you, as a manufacturer, importer, or maker of a firearm, must legibly identify the firearm as follows:

1.Serial number, name, place of business. By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or otherwise placed on the frame or receiver thereof, an individual serial number, in a manner not susceptible of being readily obliterated, altered, or removed. The serial number must not duplicate any serial number placed by you on any other firearm. The frame or receiver must also be marked with either: Your name (or recognized abbreviation), and city and State (or recognized abbreviation) where you as a manufacturer or importer maintain your place of business, or in the case of a maker, where you made the firearm; or if a manufacturer or importer, your name (or recognized abbreviation) and the serial number that begins with your abbreviated Federal firearms license number, which is the first three and last five digits, as a prefix to a unique identification number, followed by a hyphen, e.g., “12345678-[unique identification number]”...

Instructions on the Form 1 (Part K)

K. Description of Firearm and Markings.  (1) Item 4a.  If you are modifying an existing firearm, enter the name and location of the original manufacturer. If  you are creating the firearm, enter the Maker’s name, city and State. (2) Item 4b. The types of NFA firearms are listed in the definitions; (3) Item 4c. Specify one caliber or gauge. If there is another designation, indicate the designation in item 4h. (4) Item 4d. Show the model designation (if known). (5) Item 4e and 4f. Specify one barrel length and overall length in items 4e and 4f as applicable. Note: if the firearm has a folding or collapsible stock, the overall measurement is to be made with the stock extended. (6) Item 4g. Do not alter or modify the serial number of an existing firearm . Enter the existing serial number or, if a new firearm, one you create. (7) Markings: The maker is required to mark the firearm with the Maker’s name, City and State as shown in item 3b. All markings are to be in compliance with 27 CFR §§ 478.92 and 479.102. Do not alter or modify the serial number of an existing firearm. Enter the existing serial number, or if a new firearm, one you create. The Maker may not duplicate any serial number placed by the Maker on any other firearm. See 27 CFR § 479.102. 

Your dealer is most likely getting confused with the waiving of the maker marking requirements as part of the short barrel rifle/arm-brace "amnesty" registrations where the maker marking requirement was removed only for SBR (not application to an SBS as they were not part of the arm-brace to SBR amnesty) and that registration period is long since over.

Unfortunately as part of the CFR update for 479.102 that was part of the Arm Brace changes, you can also no longer engrave the required maker markings on the barrel like you used to be able to.  Those markings now have to go on the receiver.

Edited by jbntex
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An 07/02 can make and register an SBR without engraving any additional maker markings so long as the firearm hasn’t been transferred to a non-licensee.

 

As an individual, like @jbntex said above, you have to engrave your information. 

 

As it relates to 07/02, 27 CFR 478.92(a)(4)(iii)(A) states:


iii.Adoption of identifying markings.Licensees may adopt existing markings previously placed on a firearmand are not required to mark a serial number or other identifying markings in accordance with this section, as follows:

A.Newly manufactured firearms:Licensed manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another licensed manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a licensee, and the serial number adopted is not duplicated on any other firearm.

 

Edited by JoshNC
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