What are the licensing and marking requirements for a FFL to purchase new firearms from a licensed manufacturer (i.e. firearms never transferred to other than a licensee) and perform a manufacturing process for the purposes of sales and distribution?

Any person manufacturing firearms for the purpose of sale and distribution must be licensed as a manufacturer. Cerakoting is considered a manufacturing activity.

The final rule amends 478.92(a)(4)(iii)(A) and states in part that “Licensed manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another licensed manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a licensee, and the serial number adopted is not duplicated on any other firearm.”  

If assembling firearms from a new frames or receivers, the licensed manufacturer must mark the caliber or gauge, if any, on the firearms and, if a model is assigned, mark the model on the firearms.  

Last Reviewed July 22, 2022