Q: Yesterday we had a meeting with an IOI from the local office about our application for a new 07 FFL license. During which he asked what manufacturing we would be conducting and we explained AR15 assembly. He asked how we would be engraving our required manufacturing markings on each gun and we told him we send the stripped (unbuilt) receivers to another local FFL to engrave and send back to us as receivers. Today he called to inform us that sending a firearm to another FFL to have manufactures markings engraved requires a manufacturing variance otherwise it is considered a violation. I questioned this and explained that all the manufacturing and assembly is being done by us on premises and asked how manufacturing markings would be any different from having a person?s name or picture engraved. The IOI consulted his ?senior investigator? and then came back and confirmed that it was not allowed and would be a violation. Can you confirm whether or not sending a receiver to another FFL to engrave manufacturing marking requires a manufacturing variance if all manufacturing is done by us on premises? And if it is allowed can you let provide us with information on which part of the law or which ATF ruling shows that this is allowed so we can supply it to the IOI?
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