Engraving 80 and 90% Lowers

[Bill George]

Am I legal to engrave AR15 non finished lowers, called 80 or 90%? No Serial number and I will not do that.

[Kev Williams]

Depends on the lawyer and AFT agent you talk to!

I have a lot more to say about this, but I don't want to start a firestorm-- at least for now :)

For now, my advice is do what I did- google your local/closest BATF, call, ask for an agent, explain- I did, got the agent's blessing... to start ;)

[Lee Childers]

As long as it is still in the 80 percent state it is not a firearm by ATF standards. If it was going to be registered as an NFA item it would need a S/N and trust or ownership info....cosmetic engraving is irrelevant.

[Gary Hair]

Am I legal to engrave AR15 non finished lowers, called 80 or 90%? No Serial number and I will not do that.

First, according to the ATF there is no such thing as an "xx%" lower, they don't have a specification to define it, it's either a lower or it's not. If it's not then you can do whatever you like to it because it's just a chunk of metal. If it is a lower then it is regulated by the ATF and you need to be an FFL to do the engraving. Others will have a different opinion than this, but this is what my local agent told me so I'm going with what he said since he would be the one to charge me with a violation. YMMV

[Carlos Alvarez]

The following applies to the US, but not to places like CA and NY...

The agents are notoriously ill informed and contradictory. There's absolutely zero question that you can do whatever you want with an 80% lower since it's not a gun. All of the evidence I can find says it is also legal to engrave a finished one. I'd suggest that anyone who disagrees try to find the law, because I can't.

A few states like CA have further restrictions and details.

[Carlos Alvarez]

A quick search shows there are shops that will engrave finished lowers, so either they are all scofflaws (unlikely) or it is legal.

[Bill George]

A quick search shows there are shops that will engrave finished lowers, so either they are all scofflaws (unlikely) or it is legal.

Those shops must have a FFL because a lower with a serial number is considered a firearm, I know that much.

[Tim Bateson]

When I obtained my FFL, I asked this same question as I had already done a good number of them. According to my ATF agent, I did need the FFL & if there was no Serial Number on it, I was required to work with the customer & add one.
I'm not going to get into a senseless debate about what the law does & doesn't say as any lawyer can easily twist that & I'm no Lawyer.
What I am saying is "MY" ATF agent calls an 80% a gun (stupid, yes I agree). I am not going to argue with the man. The "fact" that I may or may not be able to fight that in a court isn't even up for discussion. Easier to have the FFL & follow MY agent's instructions. Gun engraving pays well, but not so good that I'm going to waste my time & money in court.

[Gary Hair]

According to my ATF agent, I did need the FFL & if there was no Serial Number on it, I was required to work with the customer & add one.

According to "my" agent... you can manufacture your own firearm and unless it falls under NFA or you want to sell it, it doesn't need to be serialized - he still recommends it, but it's not mandatory. Like I said in my other post, you need to follow the direction of the agent who will be violating you so what "my" agent says is of no consequence.

[Carlos Alvarez]

Those shops must have a FFL because a lower with a serial number is considered a firearm, I know that much.

Yeah, that logic is circular. Of course a completed lower, with or without a serial, is a firearm. That doesn't mean everyone who handles it must have an FFL.

[Kev Williams]

The following applies to the US, but not to places like CA and NY...

The agents are notoriously ill informed and contradictory. There's absolutely zero question that you can do whatever you want with an 80% lower since it's not a gun. All of the evidence I can find says it is also legal to engrave a finished one. I'd suggest that anyone who disagrees try to find the law, because I can't.

A few states like CA have further restrictions and details.

BINGO, WE HAVE A WINNER!! According to a customer of mine, who's successfully getting the notoriously ill-informed agent who served me with a C&D FIRED (with the blessing of most of his coworkers I'm told), his very expensive lawyer after scouring the *actual* laws on the books came to exactly the same conclusion. Another part of the equation according to this lawyer, the ATF only has jurisdiction concerning interstate dealings with firearms, and any non-interstate supposed gunsmithing violations must be taken up by local law enforcement. What this means essentially, is that gun shops who are actual 'gunsmiths', and DO NOT work on or deal with out of state guns, are not required to have an FFL. I'm not sure where exactly the 'engaged in the business of' provision in the law falls, but since it's up to local law enforcement to determine if a crime is being committed, it may be a moot point. Because as the laws ARE written, for law enforcement to act against you, they must find that your actions are:

-A detriment to the health and well-being of the community, OR
-Are creating a safety issue with the community, OR
-Part of criminal activity...

If law enforcement can't tie your gunsmithing actions to one of the above criteria, they have no basis for an arrest...

My customer alerted an AFT agent who was in his shop several weeks ago that he would NOT be renewing his FFL, but WOULD be remaining in the gun business, and they were more than welcome to dispute it. So far, they haven't...

=================
Reminder, ^^^ THIS ^^^ is all second hand information as of late.

However, some final notes: I have located every single law concerning firearms, the ATF's memos and addendum's, and have printed them all out and highlighted all sections of law relevant to gunsmithing, and with the exception of the 'engaged in the business of' provision that states if gunsmithing is NOT your main source of income then an FFL isn't required, all the above rings true. My concern is when gunsmithing IS your main source of income...

And finally, I was personally told by an ATF agent 3-1/2 years ago, one who isn't getting fired btw, that my gun engraving activities, which included engraving barrels, slides, receivers, machine gun trigger-packs (with owner present), ATF logged weapons (with owner present), shotguns, rifles, revolvers-- ALL were perfectly within the law, because my 'gun income' was well below 50% of my income---which is why I'd like to find out more about that part of the law. If/when I do, I'll report back :) -until then, I've said my peace...

[Bill George]

It was my understanding IF you took possession of firearm overnight or longer, it had to be entered in the "bound book" FFL holders have to maintain. I have to much going on to have the owner of the firearm stand there while the work is being done.

[Carlos Alvarez]

It was my understanding IF you took possession of firearm overnight or longer, it had to be entered in the "bound book" FFL holders have to maintain. I have to much going on to have the owner of the firearm stand there while the work is being done.

An FFL must do that because the rules for an FFL are different from the rules for everyone else. That doesn't mean that a non-FFL must do it, or is prevented from taking possession. I can hand you a gun to borrow indefinitely, no?

(Again, in the USA, I never know about CA, NY, CT, MA, etc.)

[Gary Hair]

and with the exception of the 'engaged in the business of' provision that states if gunsmithing is NOT your main source of income then an FFL isn't required, all the above rings true. My concern is when gunsmithing IS your main source of income...

Show me in writing where it says anything about "main source of income"


ALL were perfectly within the law, because my 'gun income' was well below 50% of my income


This too

FYI - "my" agent said that their office interprets "engaged in the business of" as anyone who takes money for services - period, no matter what amount or what percentage of your total business.

[Carlos Alvarez]

https://www.atf.gov/file/100871/download

Are you looking to make a profit?As noted above, if you are repetitively buying and selling firearms “with the principalobjective of livelihood and profit,” you must be licensed. Because the key is intent orobjective, the courts have made clear that a person can be “engaged in the business”of dealing in firearms without actually making a profit. In determining that intent orobjective, courts have looked to prices that an unlicensed seller charges for firearmsto determine if the principal objective of the seller is livelihood and profit. In somecases, prices reflect appreciation in actual market value resulting from having held a 6 DO I NEED A LICENSE TO BUY AND SELL FIREARMS?Guidance (continued)firearm as part of a collection, or reflect a profit intended to be used to acquireanother firearm as part of a collection. As a result, the fact that a transaction results ina profit for the seller is not always determinative.Finally, it is important to note that courts have found that you can buy and sellfirearms “with the principal objective of livelihood and profit” even if your firearmrelatedactivities are not your primary business. In other words, you can still be“engaged in the business of dealing in firearms with the principal objective oflivelihood and profit” if you have a full time job, and are buying and selling firearmsto supplement your income. ATF regulations specifically note that the term “dealer”includes a person who engages in such a business or occupation on a part-time basis.

[Gary Hair]

That doesn't mean that a non-FFL must do it, or is prevented from taking possession. I can hand you a gun to borrow indefinitely, no?

No. According to Federal Law you can only give, sell, or lend a firearm to anyone who can legally take possession of a firearm, someone who is not disqualified from possession or ownership of a firearm. This is true whether you are an FFL or not, same rules apply.

[Gary Hair]

https://www.atf.gov/file/100871/download

Are you looking to make a profit?As noted above, if you are repetitively buying and selling firearms “with the principalobjective of livelihood and profit,” you must be licensed. Because the key is intent orobjective, the courts have made clear that a person can be “engaged in the business”of dealing in firearms without actually making a profit. In determining that intent orobjective, courts have looked to prices that an unlicensed seller charges for firearmsto determine if the principal objective of the seller is livelihood and profit. In somecases, prices reflect appreciation in actual market value resulting from having held a 6 DO I NEED A LICENSE TO BUY AND SELL FIREARMS?Guidance (continued)firearm as part of a collection, or reflect a profit intended to be used to acquireanother firearm as part of a collection. As a result, the fact that a transaction results ina profit for the seller is not always determinative.Finally, it is important to note that courts have found that you can buy and sellfirearms “with the principal objective of livelihood and profit” even if your firearmrelatedactivities are not your primary business. In other words, you can still be“engaged in the business of dealing in firearms with the principal objective oflivelihood and profit” if you have a full time job, and are buying and selling firearmsto supplement your income. ATF regulations specifically note that the term “dealer”includes a person who engages in such a business or occupation on a part-time basis.

Now find something that relates to gunsmithing, not sales. Engraving firearms is gunsmithing.

[Gary Hair]

Bottom line - consider the cost to obtain and renew an FFL vs the amount you will have to pay an attorney to defend your interpretation of the law. Whether you end up being right or wrong, you'll be money ahead if you just get the FFL.

[Gary Hair]

his very expensive lawyer after scouring the *actual* laws on the books came to exactly the same conclusion

The first three years of being an FFL will cost you about $200 then $90 per 3 years after that. How many decades of license renewals would just a single hour of "his very expensive lawyer" have paid for?

Fill out the app and submit with your fee, then spend a couple of hours with your local agent for your interview, and you are absolutely legal, no uncertainty. The record keeping part is non-existent if you don't keep firearms overnight so your bound book will be empty. A single weeks worth of engraving covered the first $200 fee and I have zero time involved in paperwork. It's a pretty simple decision.

[Carlos Alvarez]

No. According to Federal Law you can only give, sell, or lend a firearm to anyone who can legally take possession of a firearm, someone who is not disqualified from possession or ownership of a firearm. This is true whether you are an FFL or not, same rules apply.

You're disqualified from legal possession of a firearm?? Ok, well obviously that's not what I meant, so... I can hand a non-felon, non prohibited possessor a gun to borrow indefinitely, no?

[Craig Matheny]

Ok not sure how this will go over... I have a "friend" who is an FBI agent got his new glock with the fbi 50 year logo on it. Not getting into what was done but I had that gun in my possession for about a week. I am pretty sure if it was illegal I would not have been given his gun. So not sure if that helps any but that is my 2cents.

[Gary Hair]

Ok not sure how this will go over... I have a "friend" who is an FBI agent got his new glock with the fbi 50 year logo on it. Not getting into what was done but I had that gun in my possession for about a week. I am pretty sure if it was illegal I would not have been given his gun. So not sure if that helps any but that is my 2cents.

Your logic here works about the same as a previous post that stated something like "everybody else is doing it so it must be ok."

[Carlos Alvarez]

My wife drives 10-15 over the limit everywhere, even with her cop friend in the car. Must be legal. I used to ride a motorcycle at ludicrous speeds following my friend who is a motorcycle cop. Must be legal.

[Kev Williams]

Show me in writing where it says anything about "main source of income"

This too

FYI - "my" agent said that their office interprets "engaged in the business of" as anyone who takes money for services - period, no matter what amount or what percentage of your total business.
18 US code 921 Definitions, subchapter 21, and in particular sections C and D:
~~~~~~~

(21) The term “engaged in the business” means—

(A) as applied to a manufacturer of firearms, a person who devotes time, attention, and labor to manufacturing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms manufactured;


(B) as applied to a manufacturer of ammunition, a person who devotes time, attention, and labor to manufacturing ammunition as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the ammunition manufactured;


(C) as applied to a dealer in firearms, as defined in section 921(a)(11)(A), 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 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)** as applied to a dealer in firearms, as defined in section 921(a)(11)(B), 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 term shall not include a person who makes occasional repairs of firearms, or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;

(E) as applied to an importer of firearms, a person who devotes time, attention, and labor to importing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms imported; and

(F) as applied to an importer of ammunition, a person who devotes time, attention, and labor to importing ammunition as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the ammunition imported.
~~~~~

** Just a note that Section D pertains to basic gunsmithing, which includes engraving-
The "occasionally" reference in the law is very clear: if you're only gunsmithing or dealing occasionally (which I at least loosely interpret as 'not my main source of income'), then the terms "gunsmith" or "dealer" shall not include you. And if you're not, as defined by their own law, a gunsmith or dealer, then an FFL is a choice, not a requirement...

[Gary Hair]

None of that has anything to do with gunsmithing, it is all about manufacture and sales. If you want to relate it to gunsmithing then you'll need a definition of "occasional" to go along with it.


18 US code 921 Definitions, subchapter 21, and in particular sections C and D:
~~~~~~~

(21) The term “engaged in the business” means—

(A) as applied to a manufacturer of firearms, a person who devotes time, attention, and labor to manufacturing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms manufactured;


(B) as applied to a manufacturer of ammunition, a person who devotes time, attention, and labor to manufacturing ammunition as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the ammunition manufactured;


(C) as applied to a dealer in firearms, as defined in section 921(a)(11)(A), 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 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)** as applied to a dealer in firearms, as defined in section 921(a)(11)(B), 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 term shall not include a person who makes occasional repairs of firearms, or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;

(E) as applied to an importer of firearms, a person who devotes time, attention, and labor to importing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms imported; and

(F) as applied to an importer of ammunition, a person who devotes time, attention, and labor to importing ammunition as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the ammunition imported.
~~~~~

** Just a note that Section D pertains to basic gunsmithing, which includes engraving-
The "occasionally" reference in the law is very clear: if you're only gunsmithing or dealing occasionally (which I at least loosely interpret as 'not my main source of income'), then the terms "gunsmith" or "dealer" shall not include you. And if you're not, as defined by their own law, a gunsmith or dealer, then an FFL is a choice, not a requirement...

[Matt McCoy]

Outside my wheelhouse and above my pay grade, but out of curiosity took a look.

One interpretation might be "gunsmithing" would apply to receiving parts from a dealer or manufacturer to fix or alter cosmetically (not including coatings). Engraving is specifically mentioned. Any SN or required marking must already be present from a manufacturer. No license is required outside of gunsmithing requirements.

Engraving a SN or required marking is where the engraver would then be considered a manufacturer.

18 U.S.C. 921(a)(21)(D) and 27 CFR 478.11

[John Lifer]

Carlos, it all depends on your state of residence. Washington and Oregon have laws now (and I expect Illinois and others on the left and right coasts) that are trying to prohibit you handing over a firearm to anyone without a background check both ways. That is Universal Background check fiasco.... But it is really irrelevant here. You are gunsmithing on a completed lower, maybe not on an 80%...... I'm working on doing some texturizing on 80% glocks. I would Never think to do it without an FFL

[Kev Williams]

None of that has anything to do with gunsmithing, it is all about manufacture and sales. If you want to relate it to gunsmithing then you'll need a definition of "occasional" to go along with it.

This is as good as it gets for a description of 'gunsmithing'; section 11, (A) and (B):

(11) The term “dealer (https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=18-USC-1335779815-816587316&term_occur=1&term_src=title:18:part:I:chapter:44:section:921)” means (A) any person engaged in the business (https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=18-USC-1104575661-816587285&term_occur=3&term_src=title:18:part:I:chapter:44:section:921) of selling firearms at wholesale or retail, (B) any person engaged in the business (https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=18-USC-1104575661-816587285&term_occur=4&term_src=title:18:part:I:chapter:44:section:921) of repairing firearms or of making or fitting special barrels, stocks, or trigger mechanisms to firearms, or (C) any person who is a pawnbroker. The term “licensed dealer” means any dealer who is licensed under the provisions of this chapter.

-Subsection (B) clearly describes what a gunsmith does... and notice they also make a distinction between "dealer" and "licensed dealer"-

The below words are all the definitions I could find in 18 U.S Code § 921:

Person
whoever
interstate or foreign commerce
firearm
firearm muffler
firearm silencer
destructive device
explosive
bomb
grenade
propelled rocket
explosive missile
mine
shotgun
short barreled shotgun
rifle
short barreled rifle
importer
manufacturer
dealer
pawnbroker
collector
indictment
crime punishable by imprisonment
fugitive from justice
antique firearm
muzzle loading rifle
ammunition
armor piercing
projectile
full jacketed projectile
armor piercing ammunition
Attorney General
published ordnance
Federal offenses
State offenses
engaged in the business
with the principle objective of livelihood and profit
terrorism
kidnapping
machinegun
school zone
school
handgun
motor vehicle
semiautomatic rifle
intimate partner
secure gun storage or safety device
body armor
==========

But- the words "gunsmith" and "gunsmithing" are nowhere to be found.

FWIW I have no axe to grind here, I don't even engrave guns anymore. I'm just an old fart who enjoys taking time to actually read the laws that I've been accused of breaking... (don't get me started on trademark law ;) )

[Tim Bateson]

This isn't going to make me any friends here, but it needs to be said...
This thread is too funny!!!!!! I really had no idea that so many of you where closet lawyers. Very laughable!!!!
Bottom line why tight rope or work the loop holes in yours or someone elses interpretation of the law? I'm loosing no sleep when I for example slap a serial number on an 80% & my customers could care less either.
Why is it so mind numbing difficult for people to just get an FFL if they need it and follow simple instructions of those looking over their shoulder (local ATF agent)? Why second guess, why look for loop holes, why defend stupid positions? As I stated before, even if I'm right and the ATF agent is wrong, I'm not going to waste my time & money to fight it.

[Bill George]

Another note, Midway USA is now selling 80% kits for Glock handguns. No SN and all the included drills and milling bits you might need. Now that does not include the internals, or the slide or the barrel and by the time you add all that in... you have the price of a new handgun or more. But if your a felon or someone else prohibited from purchasing a handgun, there you go.

Reason #1 for me not having a FFL is running my business out of my home, means the ATF can come anytime day or night for an Inspection, and #2 I would also need to get a permit from the city for that gun business and that's not going to happen.

[Kev Williams]

Laughable? I think maybe I should be offended, because I don't consider capitulating to the demands of a few Hitleresque ATF agents, who are taking the last lines of ATF ruling 2009-1 'as law', when the ACTUAL LAW, not to be confused with RULINGS which are NOT laws but only intended to enhance the actual laws, conveniently leave out the very portion OF the law that says I don't HAVE to get a damn license.

The last line reads:
Held further, any person who is engaged in the business of camouflaging or engraving firearms as described in this ruling must be licensed as a dealer, which includes a gunsmith, under the Gun Control Act.

^^^THIS STATEMENT is what WAY too many agents are hanging their hat on. However, according TO the Gun Control Act, the term DEALER or GUNSMITH shall not apply to me, because engraving guns has never been anything BUT an occasional part of my overall business. And it's NOT funny how these rulings just leave that part of the law out...

This is a link to AFT rulings-- find Ruling 2009-1, read the whole thing--
https://www.atf.gov/firearms/docs/ruling/2009-1-firearms-manufacturing-activities-camouflaging-or-engraving-firearms/download
(https://www.atf.gov/firearms/docs/ruling/2009-1-firearms-manufacturing-activities-camouflaging-or-engraving-firearms/download)
And for fun, scroll up to ruling 2010-10 and check out page 2, where once again the definitions of gunsmiths and dealers are presented, but you'll notice they still fail to actually print out the 'occasional' reference, but they DID end the sentences with "..." < yup, 3 dots--- Now THAT I find funny, because those dots are just legaleze for 'we're not printing out the entire wording of the law but our lawyers say we must at least show there IS more wording." 3 dots or not, it's intentionally misleading...

the >ONLY< gray area in the law whatsoever, is who gets to define 'occasionally'. For many a year, it's been loosely defined by the ATF in general as less than half of your business sales/income. Which is exactly what an non-Hitler ATF agent in my area told me nearly 4 years ago.

Finally, screenshot for Gary who wanted me to find something 'relating to gunsmithing'-- In 18 USC 19:21 there wasn't, but in 27 CFR 478:11 there is:

382804

finally-- you don't need to be a lawyer to read the law, just eyes...

[Gary Hair]

This isn't going to make me any friends here, but it needs to be said...
This thread is too funny!!!!!! I really had no idea that so many of you where closet lawyers. Very laughable!!!!
Bottom line why tight rope or work the loop holes in yours or someone elses interpretation of the law? I'm loosing no sleep when I for example slap a serial number on an 80% & my customers could care less either.
Why is it so mind numbing difficult for people to just get an FFL if they need it and follow simple instructions of those looking over their shoulder (local ATF agent)? Why second guess, why look for loop holes, why defend stupid positions? As I stated before, even if I'm right and the ATF agent is wrong, I'm not going to waste my time & money to fight it.

Where is that "Like" button...

[Nick Hale]

I just wanted to drop this link in. I do not think 80% lowers are anything more than a fancy piece of metal or plastic. I do not believe they require a FFL to engrave on, unless you are attempting to engrave out the inside to get it to function, for somebody else. Here is what ive seen from the ATF. List engraving, painting, camo'ing and taping? The way I read it, it states you must have a minimum FFL to do any of those listed jobs.

https://www.atf.gov/file/55461/download

[Gary Hair]

I just wanted to drop this link in. I do not think 80% lowers are anything more than a fancy piece of metal or plastic. I do not believe they require a FFL to engrave on, unless you are attempting to engrave out the inside to get it to function, for somebody else. Here is what ive seen from the ATF. List engraving, painting, camo'ing and taping? The way I read it, it states you must have a minimum FFL to do any of those listed jobs.

https://www.atf.gov/file/55461/download

That states it pretty clearly and distinctly.

[Bert Kemp]

I think this says it all

" even if I'm right and the ATF agent is wrong, I'm not going to waste my time & money to fight it."

So I think Tim means that if the ATF agent decides to arrest you even tho he is wrong, its going to cost you a lot of money and time to prove he's wrong, So why not just get the license besides that you can always make a few bucks if you have it transferring LOL

[Scott Shepherd]

I agree with both sides to some level. I'm with Tim and Gary. We have a FFL, so it's a done deal for us. We have had many of the same conversations with ATF that are reported here. We've been told that part of manufacturing a firearm is putting the serial number on it. In fact, to register as a manufacturer, you are expected to be able to make the weapon. There are special variations for people who say they manufacturer but have to sub everything out. The serial number is considered part of the manufacturing process, therefore, to put serial numbers on, you will be labeled (and treated) as a manufacturer. Keep that in mind. Not a gunsmith, but a manufacturer. The FFL for manufacturers is quite more pricey than the normal FFL.

I've had substantial disagreements with the ATF about things and backed them into a corner when they talked out both sides of their mouth. In the end, none of it matters. That paper pusher can make our life pleasant or make it a pain and it's our choice on which one we choose. I've got better things to do than fight with the ATF. Every minute I'm fighting with them, on the phone, or in court, is lost revenue from something I could have been doing. I'm not going to spend $5000 in lost earnings to try and save $200. Right or wrong, I don't care. I'm not in business to break a path for more or less ATF regulations. If I want to fight that battle, I'll step aside and fight that one on my own when I'm not trying to earn money.

We're all free to do what we want. We'll stick with engraving things for money and let someone else fight the federal government.

[Tim Bateson]

... Reason #1 for me not having a FFL is running my business out of my home, means the ATF can come anytime day or night for an Inspection, and #2 I would also need to get a permit from the city for that gun business and that's not going to happen.

I run my business from my house -
#1 - Possible, but reality is it rarely happens (I've had zero). There are too many FFL holders & too few ATF agents. They have a very difficult time even checking our books - supposed to be every 3 years (I think). I know FFL holders who haven't been audited in over 10 years. They are suppose to do it during your business hours & my hours are by appointment only. "If" they did show up, my books are up to-date & all weapons are stored in the safe. Nothing to see here.
#2 - On my local Zoning Certificate application, I gave them little reason to deny me. Although I'm legally allowed to manufacture and sell firearms, that's not what my application highlights.. outright. Instead, I really emphasized other portions of my engraving business. I was mostly vague about firearms/weapons. I did mention I provide a custom engraving service that provides the ATF with identifying and firearm tracking information.

[John C Cox]

Please consult with a lawyer who specializes in this before you take the business...

In general - if you are going to work on guns or parts of guns for money - you need the correct FFL license. If you are going to err - err on the side of caution because these regulations and their interpretations can change with the direction the political wind is blowing... And you don't want to end up in jail...

These enforcement and interpretation of these regulations also can be different from state to state...

Remember that agents often do not know the finer points of the law.. They are not lawyers... And each one seems to have a different interpretation of the law. And doing what one agent says is no guarantee that you can't end up in jail for doing it...

[Gary Hair]

In general - if you are going to work on guns or parts of guns for money - you need the correct FFL license.

So close... "parts of guns" are just pieces of metal, as far as the AFT is concerned anyway, all you need the FFL for is if you are handling what they consider to be "the firearm" - generally speaking that is the part with the serial number. Truly, nothing else matters.