Some PMFs do not have a metal plate inserted into the frame or receiver or, if they do, the plates are not large enough to accommodate the serial number as required under the amended regulations. Is there a variance for those situations?

The final rule amends 27 CFR 478.92(a)(2) and explains that an acceptable method of identifying a polymer frame privately made firearm (PMF) is by placing a serial number on a metal plate that is permanently embedded into a polymer frame or receiver, or other method approved by the Director.

A marking variance can be applied for under 478.92(a)(4), as amended, which states:
Exceptions—(i) Alternate means of identification. The Director may authorize other means of identification to identify firearms upon receipt of a letter application or prescribed form from the licensee showing that such other identification is reasonable and will not hinder the effective administration of this part.

Last Reviewed July 22, 2022