BrianPowley
~ Elite 1000 Member ~
Greetings fellow gun scratchers. For many years, I've been working as an independent sub-contractor for a lot of gunsmiths throughout the U.S.A., plying my engraving trade skills to their firearms. (Yes---I've been flying under the Radar for a long, long time...nothing illegal, just a low profile.)
We are legally required to possess a Federal Firearms License (FFL) to conduct this type of business and according to ATF's rules,I've understood that engraving is technically classified as "Gunsmithing". (I could be wrong about that)
Some time ago, a ruling or law was passed that some gunsmithing operations may be considered manufacturing operations and could require an additional manufacturing license if you made/manufactured 50 or more firearms in any year.
Now,my purpose is not to get into the "nuts and bolts" of what ATF considers to be a manufacturing function on a receiver, but nevertheless, I became involved in this case.
Here's the ruling, verbatum, to me from ATF:
....a marking variance request entails sending your various models (of firearms) to an engraver,Brian Powley,Bloomingdale, Ohio, for engraving work.
However, engraving is not considered to be "manufacturing". Please be advised that ATF has determined in ATF Rul.2009-1 that "engraving firearms is a process in which a decorative pattern is placed on the external metal of a firearm primarily for ornamental purposes. The engraving can be cut by hand or machine or pressed into the metal. There are other engraving techniques that cut designs into firearms such as checkering or scalloping. Any person who engages in an activity or process that primarily adds to or changes a firearms appearance by engraving the external surface of the firearm does not need to be licensed as a manufacturer under the Gun Control Act."
You still need an FFL for handling,smithing,transfering firearms, but you don't need a manufacturers license on top of the FFL.
And please remember---a firearm is any part of a gun that has a serial number.
We are legally required to possess a Federal Firearms License (FFL) to conduct this type of business and according to ATF's rules,I've understood that engraving is technically classified as "Gunsmithing". (I could be wrong about that)
Some time ago, a ruling or law was passed that some gunsmithing operations may be considered manufacturing operations and could require an additional manufacturing license if you made/manufactured 50 or more firearms in any year.
Now,my purpose is not to get into the "nuts and bolts" of what ATF considers to be a manufacturing function on a receiver, but nevertheless, I became involved in this case.
Here's the ruling, verbatum, to me from ATF:
....a marking variance request entails sending your various models (of firearms) to an engraver,Brian Powley,Bloomingdale, Ohio, for engraving work.
However, engraving is not considered to be "manufacturing". Please be advised that ATF has determined in ATF Rul.2009-1 that "engraving firearms is a process in which a decorative pattern is placed on the external metal of a firearm primarily for ornamental purposes. The engraving can be cut by hand or machine or pressed into the metal. There are other engraving techniques that cut designs into firearms such as checkering or scalloping. Any person who engages in an activity or process that primarily adds to or changes a firearms appearance by engraving the external surface of the firearm does not need to be licensed as a manufacturer under the Gun Control Act."
You still need an FFL for handling,smithing,transfering firearms, but you don't need a manufacturers license on top of the FFL.
And please remember---a firearm is any part of a gun that has a serial number.
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