If you’re a licensed firearm manufacturer, you’ve likely heard of an ATF marking variance. This approval allows you to manufacture firearm receivers under another company’s name or branding—an essential option for businesses seeking private-label products or expanding partnerships.
At Unbranded AR, we specialize in supporting Type 07 FFLs through the variance process and supplying high-quality lower receivers that meet your exact needs. More importantly, we take on the heavy lifting by working directly with the ATF so you can focus on running your business.
What Is a Marking Variance?
A marking variance is written approval from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) that permits a licensed manufacturer to place markings on firearms that differ from the required standards.
In practice, this means:
- • Your company can put its own logo, brand, or markings on firearms produced by another licensed manufacturer.
- • This enables custom branding, contract manufacturing, and private-label firearms while remaining fully compliant.
- • Whether you’re a smaller FFL shop expanding product offerings or a large manufacturer adding capacity, a variance gives you the flexibility to grow under your own name.
Who Qualifies for a Variance?
To participate in a variance program, you must:
- • Hold a Type 07 FFL (Manufacturer of Firearms) license.
- • Have a legitimate business need for custom markings or private-label firearms.
Examples of who may qualify include:
- • A small shop such as Joe’s Gun Shop wanting to offer branded lowers to its local customer base.
- • A large-scale firearms manufacturer looking to expand output capabilities without overextending its own production line.
- At Unbranded AR, we work with both small businesses and industry leaders. Our goal is the same in both cases: to help you grow on your terms.
Step-by-Step Process for ATF Variance Approval
- Complete the Variance Application
- Fill out ATF Form 3311.4 (Request for Marking Variance).
- Provide details about your business, intended markings, and manufacturing partner (such as Unbranded AR).
Submission to the ATF
- Once your application is ready, we make it a priority to submit it immediately.
- From there, our compliance team manages the direct communication with the ATF on your behalf—removing the burden from your shoulders.
Approval Timeline
- The ATF typically reviews variance requests in about 30 days, though timelines may vary.
- During this time, Unbranded AR tracks the request and ensures nothing falls through the cracks.
Place Your Order for Variance Lowers
- After receiving ATF approval, you’re ready to order your lowers.
- At Unbranded AR, the minimum order is just 10 lowers, because we believe you should be able to start small without limiting your long-term business goals.
- You can mix and match ambidextrous and standard lowers to hit the quantity requirement, ensuring you get exactly what best represents your brand.


Common Mistakes to Avoid
- • Submitting incomplete or inaccurate applications.
- • Forgetting required signatures or documentation.
- • Underestimating the ATF approval timeline—plan for at least 30 days.
- • Partnering with manufacturers who don’t prioritize compliance or quality.
- • At Unbranded AR, we actively help customers avoid these pitfalls by handling the application process and ensuring all compliance requirements are met.
Why Choose Unbranded AR for Variance Lowers?
- • We Handle the Process: From application submission to ATF communication, we manage the details so you can stay focused on your business.
- • Low Minimums, High Flexibility: Start with just 10 lowers and scale up as your business grows. We understand not everyone can go big from the start, and we don’t want high minimums to get in the way of your success.
- • Options for Your Brand: Choose between ambidextrous or standard lowers—or mix both—to create the product lineup that fits your vision.
- • High-Quality American Manufacturing: Every Unbranded AR lower is built with precision and pride right here in the USA. Our name stands behind the craftsmanship, so your name can stand proudly on the product.
What’s next?
The ATF marking variance process may seem complex, but with the right partner, it’s straightforward. Unbranded AR combines compliance expertise with flexible manufacturing solutions to ensure you get exactly what you need to grow your brand.
Ready to start your variance order? Contact Unbranded AR today of fill out the form below and let us handle the process for you.