[Q&A] I’m assembling an AR-15 as a manufacturer – What are the right steps to take for markings and A&D records?

So, you’re either a Type 07 or a Type 10 manufacturer and you’re assembling an AR-15 pistol or rifle from a receiver made by another FFL manufacturer.

This means that you have acquired an AR-15 receiver from another FFL (you didn’t actually make the receiver) and you are going to assemble (manufacture) it into either a rifle or a pistol and you want to know how it should be marked and how this should be handled in your records.

Let’s cover the markings and records as separate topics:

Markings

As you probably know, assembling an AR-15 rifle or pistol from a receiver with the intent to sell it is a manufacturing operation requiring a manufacturing FFL (Type 07 or 10). Also, FFL manufacturers have certain marking requirements when making a gun.

Although the receiver has been made (and marked) by someone else, you are also “making” a firearm by changing the receiver into either a pistol or rifle and therefore you must also mark it.

If needed, please go back to the ATF Compliance course and refresh yourself on the five required markings, which can be omitted, and how they must be marked.

You will need to mark YOUR FFL information on the new pistol or rifle: this includes, at a minimum, your name (as it appears on your FFL), and the city/state of your licensed premises (where you made the gun).

You will also need to ensure that the appropriate model name and caliber are marked on the firearm. Often, the caliber is marked on AR-15 barrels that you will use in your assembly and this will satisfy the caliber marking requirements.

For the serial number, you may adopt the serial number on the receiver as the serial number for the rifle or pistol asl long as it does NOT duplicate a serial number you have used before for a firearm you manufactured.

So, you’ll likely be marking: your manufacturer name, city/state, and model.

A&D Records

In your acquisition and disposition records, you should have already acquired the receiver from whichever FFL you received it from.

When you are ready to convert the receiver into a rifle or pistol, you will need to complete what we like to call a “change in form” transaction.

You will dispose the receiver to yourself (the manufacturer FFL, not you as an individual) and then re-acquire it as the pistol or rifle you made it into.

When listing the manufacturer name for this new gun, the ATF wants you to list both the original name and the new name.

I think this is stupid, but this isn’t about what I think.

So, if I make a Bushmaster lower receiver into a rifle, I would acquire it as “Bushmaster/Cleckner Rifle Co.” Also, now that you’ve made it into a pistol or a rifle, it now has a real caliber: you must include the caliber EXACTLY as it is marked on the barrel. I don’t care if the receiver says “223 Remington” if the barrel says “300 BLK,” then the rifle or pistol is chambered in 300 BLK.

As a general rule, I really dislike using “multi” at any time because it is NOT a caliber. The ATF is ok with it and some IOIs want it, but it is not right… that column in the A&D record is for calibers or gauges and “multi” is neither.

I prefer “none” in the case of a receiver, regardless of whether the receiver has “multi” or an actual caliber marked, because a receiver can not have a caliber by itself!

But, once it has a barrel, NOW it can be a certain caliber or gauge.