ATF Rule 2009-1
Held further, any person who engages in an activity or process that primarily adds to or changes a firearm's appearance by engraving the external surface of the firearm does not need to be licensed as a manufacturer under the Gun Control Act.
Held further, any person who is licensed as a dealer, which includes a gunsmith, and who camouflages or engraves firearms as described in this ruling does not need to be licensed as a manufacturer under the Gun Control Act.
Held further, any person who is engaged in the business of camouflaging or engraving firearms as described in this ruling must be licensed as a dealer, which includes a gunsmith, under the Gun Control Act.
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