SBR engraving rules

[drypowder]

Just wanted to confirm my understanding of what needs to be engraved on a SBR lower. In this case, the Form 1 was in the name of a trust, the lower is marked 'Multi' for caliber, and the barrel is stamped with the caliber (5.56 NATO).

So my understanding is the lower should be engraved:
My Trust Name
Raleigh NC [this is the city, state in Box 3B of the Form 1]

And that's it. No caliber, serial # or model name engraving required because I as a 'maker' can 'adopt' the caliber stamping on the barrel, as well as the serial # and model name on the lower.

1. Is my understanding correct?

2. OK, assuming that's all good, let's add a wrinkle (after all, this is the NFA and ATF we are talking about). The caliber stamping on the barrel is often hidden by a handguard, so this arguably does not satisfy the requirement that caliber marking should be 'conspicuous'. That said, lots of manufacturers will sell you AR's with a lower marked 'Multi' and a barrel stamped with caliber but hidden under a handguard. So presumably they are all in violation of the rule? Anyway, I guess the super safe way to go is to include caliber along with the name and address engraving. Thoughts?

 

[BigWaylon]

To be clear, none of the info you have to engrave is required to be on the lower.

A maker is required to engrave the name (matching the F1), the city & state of where it's made (has nothing to do with what's on the form), and only if not already present, the caliber...and all of that can be on the frame, receiver, barrel or pistol slide (if applicable).

All of it only has a minimum depth requirement of .003" (only the SN has a font size minimum).

Title I and Title II firearms have different requirements, so don't try to relate one to another.

Can you see the barrel engraving through an opening in the handguard? If so, I'd leave it as is. If not, I'd engrave wherever the other engraving is going, or engrave the underside of the barrel if you had plans on swapping uppers/barrels.

I have one SBR that came with the caliber engraved on the upper receiver, and I was comfortable enough leaving that as it was. The ATF definition of "receiver" is actually split between the characteristics of an AR upper and lower.

The only other one I fooled with caliber was my 6.8 SBR, where the lower was marked "multi" and I lost the barrel engraving when I chopped the barrel to 12". I engraved the caliber with a dremel between the pivot pin ears. Clearly visible if you looked for it, but nobody will ever notice it.

Everything else was dedicated SBR builds that got the caliber with my trust name or didn't have to worry about it because the barrel was marked.

One of the most clear documents on it to me is ATF Ruling 2013-3: https://www.atf.gov/firearms/docs/ruling/2013-3-adopting-identification-firearms/download

 

[drypowder]

Can you see the barrel engraving through an opening in the handguard?

If using a flashlight, yes. And who knows if it will be visible at all with some future handguard.

If so, I'd leave it as is. If not, I'd engrave wherever the other engraving is going, or engrave the underside of the barrel if you had plans on swapping uppers/barrels.

If I engrave the caliber on the lower as opposed to the barrel, that does not create any limitation on swapping uppers/barrels, correct?

 

[BigWaylon]

If I engrave the caliber on the lower as opposed to the barrel, that does not create any limitation on swapping uppers/barrels, correct?

That's a big mysterious cloudy subject.

I believe that an NFA item should always be marked with the applicable caliber when assembled. So, if you were to swap barrels/uppers down the road, you'd need to make sure it had the caliber engraved in one of the appropriate locations. Nothing wrong with the lower saying 5.56 and barrel saying something else.

Others will say you have to engrave the caliber of the F1 for the initial build, and then swap at will (which I also agree with) but with no concern for caliber markings (which I don't).

Problem is I've never seen it answered in black and white by a statute/regulation, or a ruling, or even a letter.

 

[drypowder]

That's a big mysterious cloudy subject.

As with so many things NFA/ATF, murkiness abounds. And only the law abiding give a crap about any of it.

I believe that an NFA item should always be marked with the applicable caliber when assembled. So, if you were to swap barrels/uppers down the road, you'd need to make sure it had the caliber engraved in one of the appropriate locations. Nothing wrong with the lower saying 5.56 and barrel saying something else.

Others will say you have to engrave the caliber of the F1 for the initial build, and then swap at will (which I also agree with) but with no concern for caliber markings (which I don't).

I figured all mass-produced barrels designed to mate with AR upper receivers would be caliber marked, which would make this a non-issue (setting aside the 'conspicuous' requirement for a moment).

 

[Slacker]

This bears repeating:

All of it only has a minimum depth requirement of .003" (only the SN has a font size minimum).

The trust name, city and state can be Small as heck, especially with a lazer like @Unknownpro uses.