Laser engraving gun

[Clark Pace]

I'm not a gun guy, so I don't know about the parts. I know I can engrave on wood parts. I have several people ask me about lasering their guns. Is there a particular way gun receivers or barrerl are paint. Mainly powder coated, or are they anodized. Or are they both? depending on the gun type and manufacturer? If both, what is the best way to tell besides etching. If any?

[Chris DeGerolamo]

Any AR-15 will be anodize aluminum. Barrels are likely to be steel, black oxide finish or blued. Sadly, experience plays a huge role in knowing what you can and cannot do when it comes to firearms. Being that you are not familiar with firearms will hurt too (no offense intended). Additionally, you will run into legal issues while retaining a 'firearm' in-house without an FFL (definition of a firearm is the receiver i.e. the serialized component).

[Gary Hair]

First, you need to have an FFL to engrave firearms - some will tell you otherwise but if you look at the code you'll find the real story. The ATF doesn't take kindly to gunsmithing without a license - and - YES, it is gunsmithing when you mark a firearm. Now, what's a firearm and what's not - that's the $64 question and the one that can get you into trouble. The "firearm", as far as the ATF is concerned, is the part that has the serial number. Any other part of the weapon is considered a piece of metal, wood, plastic, etc., and you can do what you like with it - as long as it's not attached to the firearm when you do it. If it is attached to the firearm then you are gunsmithing and need to be licensed and possibly do some paperwork when you do the engraving. If someone brings in just the barrel or just the wood stock then you are probably legal to laser it, otherwise you are probably not.

As for the material - they vary quite a bit - stainless steel, high carbon steel, nickel plated steel, aluminum, etc. They can be powder coated, anodized, blued, parkerized, cerakoted, etc. Ask the customer what it is, they should know - if not you can check with the manufacturer.

[Gary Hair]

Additionally, you will run into legal issues while retaining a 'firearm' in-house without an FFL

Not true Chris - you need an FFL to do the work, period. Where you do it and how long it takes has no bearing on the necessity for the FFL. The only thing time changes is if you keep it overnight then it must be logged in and out of your books.

[Chris DeGerolamo]

Gary, I think we are arguing the same point ;)

(ps: see my signature)

[Kev Williams]

As to lasering guns...You can Cermark stainless guns, and you can possibly get a useable mark from Cermark "pearl white", on blued guns but I'm not sure. You can laser black anodized AR lowers. You CANNOT laser any FFL required information unless you're using a yag or fiber and can get the required .003" minimum depth (and .0625" miniumum char. height). "Cerakoted" guns, I've done one, not much contrast. You can 'plain' laser blued guns, sometimes you'll get good contrast, sometimes not. Sometimes "less is more" on blued and anodized, so first attempt should be lower power than you might think...

That said--

I engrave a LOT of guns. Been doing it for over 30 years. I got a phone call one day from an ATF agent, wondering if I had a barrel/receiver with a certain serial number in my possession. I did, it was one of my customers. It was an 'in progress' firearm (just a barrel and receiver) that was supposed to be logged, and I wasn't supposed to have without the owner present. He got a warning, and now has me engrave the barrels first, before it 'exists'.

Meanwhile, I had a long talk with the ATF agent. Much of that talk was about engraving guns. This guy was very matter-of-fact, and had I been the least-bit smartazzed with him, he could have and likely would have, had me arrested. I was totally honest with him which he appreciated, and I wanted to know if I was breaking any laws. Actually, no. Not even by having the firearm in my possession, because, I didn't know I WASN'T supposed to have it. If I did know, then I'm breaking the law.

How about engraving? He told me it was perfectly fine to engrave anything on anyone's weapon. I can engrave a registered firearm that can't leave the owners possession as long as the owner is present. To keep such a firearm in my possession with the owner NOT present requires an FFL gunsmithing permit minimum. But I don't need a gunsmithing permit simply to engrave firearms...

This is a Q&A quote from the ATF.gov website:



Q: Is a license needed to engage in the business of engraving, customizing, refinishing or repairing firearms?

Yes. A person conducting such activities as a business is considered to be a gunsmith within the definition of a dealer.
[27 CFR 478.11]

However, this is a general 'catch-all' answer and is misleading. The actual references to dealers and gunsmiths from the code of regulations reads:

(c) Dealer in firearms other than a gunsmith or a pawnbroker. A person who devotes time, attention, and labor to dealing in firearms as a regular course of trade or business with the principal objective of livelihood and profit through the repetitive purchase and resale of firearms, but such a term shall not include a person who makes occasional sales, exchanges, or purchases of firearms for the enhancement of a personal collection or for a hobby, or who sells all or part of his personal collection of firearms;

(d) Gunsmith. A person who devotes time, attention, and labor to engaging in such activity as a regular course of trade or business with the principal objective of livelihood and profit, but such a term shall not include a person who makes occasional repairs of firearms or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;


We, as engravers, are not Dealers, and as for gunsmithing, we fall into the "makes occasional repairs of firearms" category, and as such, we are not considered "gunsmiths" and therefore not required to have a Gunsmithing permit to "occasionally" engrave guns. FWIW, no words with "engrav" exist in the code.

I got all this from the horses mouth. And, I have no less than 10 local gun dealers who bring me guns on a fairly regular basis, who wouldn't if doing so would jeopardize their business.

[Tim Bateson]

Thanks Kev, very good explanation.

My 2cents.:
The regs are not real clear on all points which leaves parts of the regs open to some interpretation. Most of the regs cover dealer owned guns, not individual owned. Also the regs don't (last I checked) cover "laser marking".

There is a lot that can be "marked" & engraved without an FFL. I mark well over 1,000 uppers every year, this year it could pass 2,000. I also engrave a lot of receivers and gun/rifle/shotgun butts/grips. I've done a good number of owner built rifles that have gone on to be inspected & approved for licensing/permits by the government. Not a single one of them have ever been rejected do to depth of "engraving", because I "mark" them not "engrave/etch" them.

**NOTE: I'm no lawyer, so read, hire a lawyer, or make your own interpretation. It's your business, so it's up to each and every one of us to do the best we can to stay within the law.

[Gary Hair]

Gary, I think we are arguing the same point ;)

(ps: see my signature)

Looks that way... What I find interesting is that the people who don't have an FFL are adamant about the "fact" that they don't need one and the people who do have an FFL understand why they do. 30 minutes for the app, $10 for fingerprinting, $7 passport photo, 3 hour interview with the local agent = no jail time or fines for me

[Tim Bateson]

To each his/her own.