As an FFL, you already know that manufacturers and importers must mark firearms with specific information required by ATF regulations. However, there are instances when you may need to request a variance. Marking variances are necessary when a manufacturer intends to manufacture and mark firearms on the behalf of another manufacturer. To receive a variance, you must fill out Form 3311.4 Application for Alternate Means of Identification of Firearm(s) (Marking Variance and send it to We have identified each step with who the point is talking about. Some of the information you will be required to list is shown below:

  1. The actual manufacturer of the firearm frame or receiver (you)
  2. The manufacturer whose markings will be placed on the firearm frame or receiver (your customer)
  3. Any other participants in the manufacturing process and a description of the process to be completed by each (your subcontractor)
  4. Where the firearm frames or receivers are shipped and/or transferred to between all of the participants
  5. The model of the firearm, if designated
  6. The caliber or gauge
  7. The serial number(s) and/or range to be used
  8. The function (semi-automatic, bolt-action, etc.) of the firearm
  9. Drawing/schematic/photograph of the proposed firearm markings
  10. Contact information of the requestor (you)
  11. Copy of the FFL of each manufacturer (you, your customer, your subcontractors)
  12. Copy of the Special (Occupational) Tax Stamp for each manufacturer, if applicable (you, your customer, your subcontractors)

We are not providing legal advice, so remember to discuss any questions with your attorney.  You can get all of the details by downloading the ATF’s Guide for Requesting Marking Variances.

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