This is a very common question asked when discussing NFA Trusts. Many people out there can confuse others into believing that it’s a big disadvantage that you are required to engrave something on your NFA firearm if it’s in an NFA Trust.
ATF Form 4’s
If you are completing an ATF Form 4 Application for Tax Paid Transfer and Registration of Firearm, then no. It does not matter if the NFA firearm was transferred as an individual or into an NFA Trust. Only manufacturers, importers, and makers of firearms are required to engrave firearms. If you are the buyer of an already manufactured firearm, receiver, Silencer, Short Barreled Rifle (SBR), Short Barreled Shotgun (SBS), Machine Gun, or Any Other Weapon (AOW) then it already has the manufacturer’s markings on the firearm listed on the Form 4 so you are not required to engrave anything additional onto the NFA firearm.
ATF Form 1’s
If you are completing an ATF Form 1 Application to Make and Register a Firearm, then… YES. You are either the manufacturer or maker of the firearm and must meet the engraving requirement. This means the NFA firearm must be marked conspicuously on the frame, receiver, or barrel with the name of the trust and the city and state (two-letter postal abbreviation acceptable) where the SBR is made. See 27 C.F.R. § 479.102(a)(2). For purposes of the marking requirement, there is no difference whether the maker is an individual or an NFA Trust.
What needs to be engraved on my NFA firearm?
- Name of the individual or entity that made/registered the NFA firearm.
- Location (City and State) where the NFA item was made.
- Caliber of the registered NFA firearm.
- Serial Number of the registered NFA firearm.
- Model of the registered NFA firearm.
To comply with 27 CFR §§ 478.92 and 479.102., the engraving or stamping (impressing) of ALL required information must be to a minimum depth of .003 inch and in a print size no smaller than 1/16 inch. This is important when you are selecting an engraver for your NFA markings. Many decorative engravers will not meet the ATF depth requirement.
EXAMPLE 1:
You purchased an Anderson Manufacturing Frontline QR-16 rifle that has a 16-inch barrel. You want to put a 10-inch .300 Blackout barrel on it and make it into an SBR.
NOTE: This rifle is advertised as a 5.56 NATO caliber. However, the receiver says, “MULTI” meaning it can shoot multiple different calibers. You CAN NOT put “MULTI” as the caliber on an ATF Form 1. In this case, the caliber would be “.300” since that is the caliber barrel you will be installing. Here are the current manufacturer markings that are already on the rifle, and what you used to fill out the information on the Form 1:
ANDERSON MANUFACTURING
HEBRON, KY
.300
12345678
After the ATF has approved the Form 1, you must engrave the firearm as the maker, before you put the new 10-inch barrel on it, to comply with NFA laws. You have some choices of where to engrave the firearm. The frame, receiver, barrel, or pistol slide (if applicable) are all acceptable under the law. For practical purposes, especially with AR-type firearms, engraving the lower receiver is usually the best option. As such, you will be able to swap upper receivers without needing to re-engrave the firearm.
Individual
You must include your full name and location (City and State) based on the applicant (you) address and what was entered in box 3b. of the Form 1. Because the original manufacturer (remember, you are the maker) already engraved the serial number, model, and caliber, you are not required to re-engrave this information. Even though the caliber is now .300, “MULTI” does not need to be changed on the receiver and you do not engrave .300 onto the receiver as long as the barrel is marked with the caliber and it is “conspicuous” which means it can easily be seen without removing a hand guard, it should be acceptable. Do not alter or modify the serial number of an existing firearm.
JOHN DOE
RIVERTON, UT
NFA Trust
You must include the name of your Trust and location (City and State) based on the Trust address and what was entered in box 3b. of the Form 1. The full city name must be included, but the state can be abbreviated. Because the original manufacturer (remember, you are the maker) already engraved the serial number, model, and caliber, you are not required to re-engrave this information. Even though the caliber is now .300, “MULTI” does not need to be changed on the receiver and you do not engrave .300 onto the receiver as long as the barrel is marked with the caliber and it is “conspicuous” which means it can easily be seen without removing a hand guard, it should be acceptable. Do not alter or modify the serial number of an existing firearm.
JOHN DOE NFA TRUST
RIVERTON, UT
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EXAMPLE 2:
You are making an NFA firearm from scratch using an 80% lower receiver that you want to mill out and install a 10-inch .300 Blackout barrel to create an SBR. After the ATF has approved the Form 1, you must engrave the firearm as the maker, before you mill out the lower receiver and put the new 10-inch barrel on it, to comply with NFA laws. The location (City and State) is based on the applicant’s address and what was entered in box 3b. of the Form 1. The full city name must be included, but the state can be abbreviated.
To comply with 27 CFR §§ 478.92 and 479.102., the engraving or stamping (impressing) of ALL required information must be to a minimum depth of .003 inch and in a print size no smaller than 1/16 inch. This is important when you are selecting an engraver for your NFA markings. Many decorative engravers will not meet the ATF depth requirement. You have some choices of where to engrave the firearm. The frame, receiver, barrel, or pistol slide (if applicable) are all acceptable under the law. For practical purposes, especially with AR-type firearms, engraving the lower receiver is usually the best option. As such, you will be able to swap upper receivers without needing to re-engrave the firearm.
Individual
All information must match what was entered on the Form 1. You must include your full name and location (City and State) based on the applicant (you) address and what was entered in box 4. a. The caliber as entered in box 4. c. A model is not required, but if you included a model on the Form 1 in box 4. d. it must be engraved. The serial number as entered in box 4. g. The Maker may not duplicate any serial number placed by the Maker on any other firearm.
JOHN DOE
RIVERTON, UT
COOL SBR
.300
001
NFA Trust
All information must match what was entered on the Form 1. You must include the name of your Trust and location (City and State) based on the Trust address and what was entered in box 4. a. The caliber as entered in box 4. c. A model is not required, but if you included a model on the Form 1 in box 4. d. it must be engraved. The serial number as entered in box 4. g. The Maker may not duplicate any serial number placed by the Maker on any other firearm.
JOHN DOE NFA TRUST
RIVERTON, UT
COOL SBR
.300
001
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If you have any questions, please contact us and we can help answer questions and help you complete the ATF Form 1.