New component parts to be numbered ?

[Dellboy]

So i have a 10/22 barrel in the safe and the local club gun need a new barrel fitted .

I obtained the barrel before all this number thing came in so booked it in (rfd) as ruger barrel no number . However now im selling it to the club i need a number on it , i cant transfer from the original as it didnt have one  so do i ramdomly make up a number and put that on the club certificate with the rifle ? or do i transfer the rifles action number onto the barrel ?

Before someone mentions asking firearms  apparently the guy with the answers is away for a fortnight ...

oh and the old barrel is being scrapped .

[terryh]

Mr Boy

Must have missed something but do not believe any of my rifles have the serial number on the barrel, the number’s on the action? 

Are you sure about this???

Terry

[srvet]

I believe Terry is correct that the barrels are not serial numbered but possessing a chambered blank needs to be listed on an FAC

[Webley]

It is a new rule/law, all new significant component, pressure bearing parts of a firearm need to be numbered now. The police system is not set up to receive these from what I understand. It wants one serial number per gun, now it will need 3 or 4 logged for each gun. Breach,/barrel, bolt, receiver and uppers and lowers for ar types.

I have seen a post from Lantac who make AR type guns where they are getting everything numbered up for a batch of new guns.

Edit.

https://m.facebook.com/story.php?story_fbid=3438208749577957&id=148402105225321

That should be a link to their facebook post about it.

Matt

Edited February 28, 2020 by Webley
Adding link.

[Dellboy]

1 hour ago, srvet said:

I believe Terry is correct that the barrels are not serial numbered but possessing a chambered blank needs to be listed on an FAC

and you cant list on an fac without a number and manufacturer

[Popsbengo]

38 minutes ago, Dellboy said:

and you cant list on an fac without a number and manufacturer

I had until very recently a chambered barrel without any numbering listed on my FAC.  I sold it to a RFD with no problem.

Can someone point us towards a reference that explains this 'new process' please?

[AJW7088]

With reference to the changes here is a link to the Home Office Circular about them;

https://www.gov.uk/government/publications/circular-0102019-firearms-regulations-2019-and-the-firearms-amendment-no2-rules-2019/0102019-firearms-regulations-2019-and-the-firearms-amendment-no2-rules-2019

In actual fact the changes to the EU Firearms Directive require each "member state" to ensure the essential components are suitably marked and details recorded.  The changes to UK law have had the effect of requiring RFDs to record the new information on their registers, perhaps because the NFLMS is not yet capable of doing so (and that may be because Government thought the UK may have been clear of the EU requirement by this time) .  The amended Directive does not specify that all these details also have to be shown on the possessor's permit (an FAC/SGC here), although it may be the case that, as far as possible, the details shown on any one essential component will be the same on each of them for that particular firearm.  Where this will get overly complicated is when essential components are changed out and the new one has different details...

The new essential component marking requirement applies to firearms manufactured within the UK or EU on or after 14th September 2018 (or those imported into the UK or EU on or after that date).  For firearms manufactured or imported before that date then the addition to the details currently recorded would be the country or place of manufacture (if known).

In terms of the OP's question, it would seem that if the replacement barrel was manufactured or imported before 14th September 2018 then the new essential component marking requirements do not apply to it (and in any case would not (yet) be shown on a Club FAC).  The RFD register only has to record the new marking details for essential components to which the Directive applies, it is not retrospective.

If it was manufactured or imported on or after that date then they do apply and it should have been marked.  Whilst the minimum font size, alphabetic and numeric formats are specified in the technical specifications to the Directive amendment, the formats for the marking are not, so the markings simply need to comply with the Directive requirement, for example state of manufacture could be shown as UK.

I hope this helps?!!

Adrian

[Popsbengo]

Adrian,  bloody brilliant mate, thanks

[Catch-22]

I’m just in the process of having a new rifle with a clutch of chambered barrels sent over from the US.

Ive been advised that all major component parts  (action, barrels, bolts) have the following details engraved on them;

- serial number

- country of manufacture

- name of manufacturer

- model (where relevant)

it’s a huge PITA!

[Re-Pete]

You have a 10 year old rifle, and a couple of unmarked blanks that you got in 2019. You have no idea of the manufacturing date for these blanks...........

You fancy a change of calibre, so you get a variation and it adds "spare x calibre barrel" to your FAC. You then get the rifle re-barrelled using one of the aforementioned blanks, and the original barrel plus the newly chambered and proof marked one is handed back to you by your gunplumber.

After a while, you decide to sell the rifle privately, face to face.

I can't see how it would make any difference to the above scenario..............can anyone else?

Pete

 

.

 

[Dellboy]

4 hours ago, Re-Pete said:

You have a 10 year old rifle, and a couple of unmarked blanks that you got in 2019. You have no idea of the manufacturing date for these blanks...........

You fancy a change of calibre, so you get a variation and it adds "spare x calibre barrel" to your FAC. You then get the rifle re-barrelled using one of the aforementioned blanks, and the original barrel plus the newly chambered and proof marked one is handed back to you by your gunplumber.

After a while, you decide to sell the rifle privately, face to face.

I can't see how it would make any difference to the above scenario..............can anyone else?

Pete

 

.Well from another slant as an RFD you are expected to list manufactures name and number on the buyers RFD (OR MAYBE IVE READ THAT WRONG ) so what happens to blackpowder revolver cylinders listed on a ticket as no manufacturer no number  and the same with moderators ?

 

 

[Dellboy]

7 hours ago, AJW7088 said:

With reference to the changes here is a link to the Home Office Circular about them;

https://www.gov.uk/government/publications/circular-0102019-firearms-regulations-2019-and-the-firearms-amendment-no2-rules-2019/0102019-firearms-regulations-2019-and-the-firearms-amendment-no2-rules-2019

In actual fact the changes to the EU Firearms Directive require each "member state" to ensure the essential components are suitably marked and details recorded.  The changes to UK law have had the effect of requiring RFDs to record the new information on their registers, perhaps because the NFLMS is not yet capable of doing so (and that may be because Government thought the UK may have been clear of the EU requirement by this time) .  The amended Directive does not specify that all these details also have to be shown on the possessor's permit (an FAC/SGC here), although it may be the case that, as far as possible, the details shown on any one essential component will be the same on each of them for that particular firearm.  Where this will get overly complicated is when essential components are changed out and the new one has different details...

The new essential component marking requirement applies to firearms manufactured within the UK or EU on or after 14th September 2018 (or those imported into the UK or EU on or after that date).  For firearms manufactured or imported before that date then the addition to the details currently recorded would be the country or place of manufacture (if known).

In terms of the OP's question, it would seem that if the replacement barrel was manufactured or imported before 14th September 2018 then the new essential component marking requirements do not apply to it (and in any case would not (yet) be shown on a Club FAC).  The RFD register only has to record the new marking details for essential components to which the Directive applies, it is not retrospective.

If it was manufactured or imported on or after that date then they do apply and it should have been marked.  Whilst the minimum font size, alphabetic and numeric formats are specified in the technical specifications to the Directive amendment, the formats for the marking are not, so the markings simply need to comply with the Directive requirement, for example state of manufacture could be shown as UK.

I hope this helps?!!

Adrian

well it must have arrived here before that date then   thanks

[AJW7088]

Sure, and if the authorities wish to take action over a lack of details recorded on an RFD register regarding an essential component then it is necessary for them to prove that the essential component was manufactured or imported into the UK or EU after the 14th September 2018. 
The authorities are only likely to be able to gain that information from the same sources that the RFD could have done (for example, import documents held by the RFD who imported the item, which may also be available through UK import/border records).

If the date of manufacture or import is simply unknown then it would not be possible to prove the alleged offence.
 

These provisions do not introduce a requirement that RFDs must be able to prove dates of manufacture or import, although the chain leading back to that point might be available by working back through RFD registers and the NFLMS (if the firearm had been on certificate at some point previously), accepting that an item may have passed through several registers.

If an RFD wanted to try and follow that chain back to answer the date question then they could try, but I am not sure the UK authorities expect that. If one RFD in a chain has ceased to trade then the chain will end there (as far as an enquiring RFD is concerned) I guess.

Another triumph of European firearms licensing law...!

[baldie]

I find it strange that no RFD I know has ever been made aware of this "Law'

Its also a European law. We are not in Europe. Point 5 at the top of the page states that , as I read it.

I have not seen any of this "required" info, being stamped on ANY new rifle, from Europe either.

 

[terryh]

...... Dave, as always to the point and direct 😁

That was the ‘are you sure about this?’ in my original post, as if it is true I’ve had firearms transferred onto my FAC that have been manufactured in Europe and the UK which only have any form of identification number on the receiver.

One of these I collected from proof, which begs a question, if it was ‘law’ why would the proof house releasing an ‘illegal’ firearm??

Caveat: I waited for this rifle to come out of proof last year and had a discussion generally while there. The proof master did say that CIP had proposed every component be ID’ed - but the way it was written every component, small screw, springs, etc was included so it was thrown back. Is this some legacy rumour etc?

T

[AJW7088]

52 minutes ago, baldie said:

I find it strange that no RFD I know has ever been made aware of this "Law'

Its also a European law. We are not in Europe. Point 5 at the top of the page states that , as I read it.

I have not seen any of this "required" info, being stamped on ANY new rifle, from Europe either.

 

Hello,

Point 5 of the HO Circular includes;

”Until EU exit negotiations are concluded, the UK remains a full member of the European Union and all the rights and obligations of EU membership remain in force. During this period the government will continue to negotiate, implement and apply EU legislation.”

The EU exit negotiations will not be completed before the end of December 2020 (the negotiations are separate from, and subsequent to, the UK having left the EU). Point 5 is therefore saying that during the current negotiations the UK will continue to apply EU legislation. In this instance that is being done through the Firearms (Amendment)(No2) Rules 2019, in particular Rule 2(5).

As to there being no briefing for RFDs on these new rules then I am not surprised. I think that the HO had thought UK would have been clear of this negotiation period (because we would have left the EU earlier than we did) and therefore hadn’t planned to need to introduce these new rules. I expect the HO would say their Circular and the Rules themselves are online and should have been read - rather ignoring how anyone would know to do so, save for the occasional references to their introduction by some shooting organisations perhaps.

In relation to the apparent lack of marking on essential components currently arriving from within the EU, then if these had actually been manufactured within the EU, or imported prior to 14th September 2018 but had been stored before their subsequent transfer to the UK then they do not need to have been marked. Again, the UK authorities would have to prove the date of manufacture or UK/EU import, which may not be possible.

[AJW7088]

11 minutes ago, terryh said:

...... Dave, as always to the point and direct 😁

That was the ‘are you sure about this?’ in my original post, as if it is true I’ve had firearms transferred onto my FAC that have been manufactured in Europe and the UK which only have any form of identification number on the receiver.

One of these I collected from proof, which begs a question, if it was ‘law’ why would the proof house releasing an ‘illegal’ firearm??

Caveat: I waited for this rifle to come out of proof last year and had a discussion generally while there. The proof master did say that CIP had proposed every component be ID’ed - but the way it was written every component, small screw, springs, etc was included so it was thrown back. Is this some legacy rumour etc?

T

Hello,

Unless the Proof Master was able to prove that date of manufacture and/or import into the UK/EU then there would be no way of telling whether the essential components of your firearm each had to be marked. The rules are not retrospective so firearms made or imported before 14th September 2018 are not caught by the new requirement.

In any event essential components that should have been marked but haven’t aren’t illegal to possess. The obligation to ensure that they are marked falls to the Member State. The UK now has domestic law requiring the new markings to be recorded by an RFD but if the items have not been marked the RFD could not do that. The rules do not include any requirement for the RFD to create markings, that would have been for the manufacturer to have done. At import the items should have been refused entry if they were unmarked but should have been. That would be why a post above indicates US manufacturers may indeed be applying these markings, as a UK and EU import requirement.

In the development of the EU Directive amendment CIP contributed to the discussions, but the decision on exactly what to require fell to the EU Council rather than CIP.

I appreciate how poor this situation is, and how difficult it is to identify which essential components need marking (based on knowing when they were made or imported). This is more complex because it is their import into the EU that might matter, not simply import into the UK...

[John MH]

This ill thought through law has nothing to do with the Proof Houses or the Proof Masters as far as I can see.

[AJW7088]

21 minutes ago, John MH said:

This ill thought through law has nothing to do with the Proof Houses or the Proof Masters as far as I can see.

Yes, I think that is right, in terms of any enforcement of these rules, though I believe the Proof Houses are entitled to reject an arm or barrel submitted for proof if it is not properly marked. I recall that the Rules of Proof only refer to a “serial number”, so essential component markings may still not (yet) be caught. 
 

[Catch-22]

I think the law will mostly be applied once HMRC checks component parts on arrival to the UK.

This is why I’ve just had everything engraved to negate any possible arguments and seizure by customs.

[terryh]

1 hour ago, John MH said:

This ill thought through law has nothing to do with the Proof Houses or the Proof Masters as far as I can see.

John,

might very well be the case but the guy was showing me their new laser engraving machine and other similar apparatus when talking about the silliness of the proposed CIP requirements for ‘every’ component to be uniquely marked, not saying it was linked to this, just passing on - hence ‘caveat’ in my mail.

All I know as a ‘fact’ is I’ve had firearms that fall after this cut off date transferred onto my FAC that are both custom and factory by RFD’s who I’m pretty sure are ‘not’ checking and recording that each components carries a serial number.

Am I in breach of the law in owning these firearms as they do not comply, can I sell them etc.etc.

All a bit hear say, opinion and nothing ‘in writing’ (so to speak).

T

[Dellboy]

Just unwrapped 2 brand new Tikka  recievers and bolt marked  barrel unmarked except for proofing

[baldie]

I'm going to ask My licensing Dept, and also the proof house.

I've had no correspondence from either on the subject.

It is not reasonable to expect RFD's to scrutinise European law to look for stuff like this. Much less to expect laymen to understand it.

What is even more unacceptable is to have to have every part engraved [ i would imagine it will be pressure bearing parts ] by either the proof house [ and I would guess they will refuse, as they do not like, or want to have to strip guns down ] or expect gunsmiths to shell out for an engraving machine. If it happens, the proof fees will treble.

I would love one, but the costs are horrendous.

1 minute ago, Dellboy said:

Just unwrapped 2 brand new Tikka  recievers and bolt marked  barrel unmarked except for proofing

Tikka's and the like have aways had the last 3 digits of the serial number on bolts. Simply helped keep them together.

Given the current state of UK/EU relations, I seriously doubt the UK will enforce it. Negotiations may still be underway, but we are categorically NOT european members anymore.

 

[AJW7088]

Yes, we have certainly left the EU (31st January 2020) but these rules came into force before we did so (12th December 2019), so we have now been left with them as we go through the transition period, as we have with the previous changes to our domestic law brought about by the EU Firearms Directive. 

I entirely agree that the expectation on RFDs or anyone else to spot these changes and understand the detail is unreasonable, and I share the view that enforcement is unlikely to be a key priority now we have gone (and didn’t want this amendment in the first pace really). Give the real difficulty for the authorities in proving dates, I can’t see it being very achievable even if someone wanted to enforce it.

I hope that the policing expectation will be that RFDs record the additional details if they are present, but have no responsibility for whether they are present or not. 

[Mattnall]

On 2/29/2020 at 7:14 AM, baldie said:

I find it strange that no RFD I know has ever been made aware of this "Law'

Its also a European law. We are not in Europe. Point 5 at the top of the page states that , as I read it.

I have not seen any of this "required" info, being stamped on ANY new rifle, from Europe either.

 

Well, you know of at least two, myself and another of the old CSR shooting crowd and I have had a letter from the neighbouring county firearms department about this (it did upset my own FEO when they found out). I find it hard with all the social media/shooting fora exposure this has had that anyone using such platforms doesn't know about this.

As an EU law we had to take it into UK law because we didn't leave the EU before the law came in to force (mid December). This was automatic and the problem now comes in finding the parliamentary time, and even the will, to repeal this.

Most of Europe, according to a couple of my sources, are refusing to do this saying it's unworkable and it will not help in reducing crime, however it IS law in the UK and if 'they' want to cause trouble for shooters (RFD/manufacturers) then this is a good place to start.

I have spoken to a couple of large firearm importers and they are looking into whether this will be complied with here. I have also heard that some firearms departments aren't going to enforce it (until they want to get rid of the RFDs perhaps, etc) and it only applies to RFDs and not FAC holders. The (various) numbers on a firearm only get reported as far as the RFD register and not on the FAC or to the firearms departments upon transfer as this is not provided for in the law.

I believe that one proof house is offering to engrave the components to the required standard for a small fee per item. No surprise there.