The final rule provides that licensees who acquire privately made firearms (PMFs) may have PMFs engraved on-the-spot by another person under their direct supervision. What does “under direct supervision” mean?

Licensees may mark PMFs themselves or they can take a PMF to any person, licensee or non-licensee, who has the ability to mark the PMF.  However, such other person may only mark the PMF on-the-spot under the direct supervision of the original federal firearms licensee (FFL). This person shall mark the PMF with the original licensee’s abbreviated FFL number in accordance with 478.92(a)(2).  

PMFs are marked “under the direct supervision” of the FFL who received or acquired the PMF when the FFL required to mark the PMF has not disposed of the PMF to the person doing the marking. In no case may the licensee who receives or acquires a PMF dispose of an unmarked PMF, whether to a licensee or non-licensee, until the firearm is properly marked, and the serial number is recorded in the record of the licensee who received or acquired the PMF.  

Last Reviewed July 22, 2022