All firearms you make must have the required markings.
It seems simple enough, but as you’ve probably realized by now, there are plenty of exceptions/special rules.
First, the basics of manufacturer markings. In the next lesson, we’ll cover variances.
Required Markings
As we covered in Lesson 2.6 – Firearm Markings under the GCA, there are 5 markings that every firearm must have.
This is a bit of a review of Lesson 2.6 included here for making information easy to find.
All required firearm markings must be made with Roman letters (e.g. “A, B, C”) and/or Arabic numerals (e.g. “1, 2, 3”).
These markings are:
- Serial Number
- Manufacturer Name
- City and State of Manufacture
- Model (if known)
- Caliber (if known)
You should commit these to memory – every firearm you manufacture must have these marked conspicuously (easily to see) and marked in the following manner and locations:
Serial Number: The serial number must be marked at least 0.003″ deep, it must be at least 1/16″ tall, and it must be conspicuously placed on the firearm’s frame or receiver in a manner that is not susceptible to obliteration (i.e, marked in metal).
Manufacturer Name, City, and State of Manufacture: Each of these markings must be at least 0.003″ deep and must be conspicuously marked on the firearm’s frame or receiver in a manner that is not susceptible to obliteration (i.e, marked in metal).
Model (if known), and Caliber (if known): Each of these markings must be at least 0.003″ deep and must be conspicuously marked on either the firearm’s frame or receiver, barrel, or slide (if a pistol).
Serial Number
The serial number must be unique to the manufacturer. This means that Glock may have only one firearm with the serial number “1234.” Glock may NOT have one Glock model 17 with the serial number “1234” and a Glock model 19 with the serial number “1234” Even though those serial numbers would be unique for each model, the manufacturer may not duplicate a serial number on any other firearm it makes.
As a note, “01,” “001,” “A001,” and “B001” are all unique serial numbers. Therefore, you can have many “#1” firearms (this can be helpful for marketing).
The serial number may not be changed or modified without ATF approval. If a serial number is obliterated – STOP! This is a serious issue, and you will be in big trouble if you are caught with it. You must immediately notify the ATF and in some cases, they will issue you a unique serial number that you can mark on the firearm.
Even if you destroy a firearm by cutting or crushing it, DO NOT REMOVE THE SERIAL NUMBER. It is not needed for tracking purposes, but it looks very suspicious and might be hard to prove it was removed after the object was not a firearm.
The serial number must have at least one number. Therefore, “Cleckner1” may be a serial number, whereas “Cleckner” may not.
Manufacturer Name
The name on the firearm must be marked EXACTLY as it appears on the manufacturer’s FFL. For example, if an FFL only lists “Joe Bob’s Custom Guns and Furniture Repair, LLC” as the company name, then that entire name, including the “LLC” must be marked on every firearm made.
If the FFL wants to mark “Joe Bob’s Custom Guns” on the firearm, then that must be added as a trade name on the FFL. You can do this by adding “trade names” to your FFL. You can have as many as you like (as long as they don’t conflict with another manufacturer’s name).
City and State of Manufacture
Similar to the manufacturer’s name, the city and state must match whatever is on the FFL.
Often, bolt-action rifle manufacturers mark the city and state on the barrel after the rifle is completely assembled. This is a problem if the manufacturer sells the rifle’s receiver by itself – it is a firearm entering commerce, so it must have all the required markings.
As an example, Remington sells bare model 700 receivers to Brownell’s. Because the model 700 receivers typically don’t have the city and state marked on them, these bare receivers to Brownell’s are marked on the bottom with “Ilion, NY.” Although this marking will be covered by a stock once assembled into a complete rifle, the marking is conspicuous in its condition as shipped to Brownell’s. It is up to the Type 07 FFL who manufactures the receiver into a complete rifle to conspicuously mark their city and state on the completed firearm.
Model (if known)
As you’ve surely noted, I’ve included “if known” behind the “model.” This is because it is sometimes unclear what the model of the firearm will be when it is still just a frame/receiver. For example, Glock 17 and Glock 34 use the same frame. If Glock wants to send that frame out to another FFL to get cerakoted, all five markings (if known) must be present because it is being transferred off of Glock’s FFL. In this case, the model of the particular frame is not yet known (it can end up being a Glock 17 or a Glock 34) so it isn’t required to be on the frame at this step. Once the frame is assembled into a complete firearm, however, and the model is known, it must be marked on the firearm.
Caliber (if known)
Similar to the model, the caliber may not be known if the firearm is only a frame or receiver. For example, an AR-15 receiver, without a barrel attached, does not yet have a caliber. Some manufacturers mark their receivers with “multi” or with the caliber of the rifles they typically sell. If you assemble the receiver into a complete rifle, you have just manufactured a rifle from a receiver and must mark it properly – including the new caliber.
Adoption of Markings
A manufacturer which assembles a frame or receiver manufactured by another FFL into a complete firearm must add their own markings. Some markings on the firearm may be adopted by the manufacturer and one MUST be adopted: the serial number.
We’ll cover this a bit more in the lesson on Making a Firearm from Another Firearm/Receiver
For example, if you are “Tim’s Guns” and you purchase a Remington 700 receiver from Brownell’s, and you assemble the receiver into a complete rifle, you must mark your manufacturer name (“Tim’s Guns), your city and state (e.g. “Phoenix, AZ), the model of that particular firearm (e.g. “The Tim-anator”), and the caliber (e.g. “308 Win.”). If you used a receiver that already had “Phoenix, AZ” and/or “308 Win.” on it, then you may adopt those markings and there’s no reason to re-mark the same thing.
You may NOT mark a new serial number – when the ATF traces the firearm, there can be no confusion about what the serial number is, and it must match the manufacturer all the way to the customer.
Importer’s Markings
All imported firearms must be marked with the country of manufacture.
The importer of a firearm must include their importer name (on their FFL) and their city and state on the gun.
If any of the other required markings are not present, they must be added by the importer.
In certain instances where the original markings are not made in Roman letters or Arabic numerals, (e.g. a serial number marked “ДМ7639И”), new markings must be applied that match ATF requirements. This is the only instance in which a new serial number may be added.
The serial number uniqueness requirement also applies to importers – this can be an issue. It is not unreasonable to assume that an importer might receive two different firearms from two different manufacturers with the same serial number.
Manufacturing Marking Best Practices
In your manufacturing process, you should identify exactly when a firearm becomes a firearm.
I recommend even going so far as to make a sign for the machine which actually makes a firearm so that it’s clear that raw material goes in, but a firearm comes out.
Remember, it is NOT when an item is completely manufactured when it becomes a firearm, it is when it crosses the line into being “readily convertible.” Therefore, the step in your process where it crosses that line and becomes a firearm is likely to be somewhere well before your company is “finished” with the product.
Once an object crosses this line, it needs to have a serial number. According to ATF Ruling 2012-1, a manufacturer must have the required markings placed within 7 days.
FROM ATF RULING 2012-1 Held further, it is reasonable for a licensed manufacturer to have seven (7) days following the date of completion (to include a firearm in knockdown condition, i.e., complete as to all component parts, or a frame or receiver to be sold, shipped, or disposed of separately) in which to mark a firearm manufactured, and record its identifying information in the manufacturer’s permanent records.
BE VERY CAREFUL here – do not get complacent. During an inspection, if the ATF finds unmarked firearms (or frames or receivers), it will raise a red flag, and you’ll need to be able to prove that it has been less than 7 days since the firearms were made.
I strongly advise that you mark firearms the same day they were made if possible. This ensures that you don’t accidentally forget to mark frames or receivers.
Of course, if the model and caliber are not known at the time, they may be omitted.
Where this becomes an issue very often for manufacturers: sending components out for manufacturing processes. For example, if you send out a frame or receiver for heat treating or coating, you must have the required markings on it before sending it out (or you’ll need a variance).