May a licensee take a privately made firearm (PMF) into inventory if it does not have equipment necessary to mark firearms?

All licensees are required to mark all PMFs they acquire. Licensees may mark PMFs themselves or they may have any person, licensee or non-licensee, mark PMFs on their behalf. However, such other person may only mark a PMF on-the-spot under the direct supervision of the original federal firearms licensee (FFL). In this scenario, the person physically marking the PMF for the FFL will mark the PMF with the acquiring licensee’s abbreviated FFL number in accordance with 478.92(a)(2). In addition, a licensee who marks a PMF for the FFL who acquires the PMF need not log the PMF into its records.

Licensees have seven days to properly mark a PMF it acquires into inventory.  

Last Reviewed July 22, 2022