California’s laws regulating unfinished frames and receivers, commonly known as “80% lowers” or “polymer frames,” have undergone significant changes with recent legislation. This guide provides a factual overview of the key statutesu2014AB-1089, SB-118, and the Unserialized Firearm Actu2014effective through 2026, outlining compliance requirements for retailers and builders, what activities remain lawful, and the state’s serialization process. It is essential for anyone involved with these components to understand the statutory framework to ensure adherence to California law.
Understanding the Core California Statutes
Three primary statutes govern unfinished frames and receivers in California. Assembly Bill 1089 (AB-1089), effective July 1, 2024, redefines “firearm” to include unfinished frames and receivers and imposes new requirements on their sale and transfer. Senate Bill 118 (SB-118), effective January 1, 2025, mandates that licensed firearms dealers conduct serialization services. The Unserialized Firearm Act (Penal Code sections 29180-29184), which has been in effect, establishes the process for applying to the California Department of Justice (CA DOJ) for a unique serial number to be engraved on a firearm built for personal use. These laws work in concert to regulate the entire lifecycle of these components.
AB-1089: The Pre-Serialization and Sales Framework
AB-1089 (Stats. 2023, ch. 292) significantly alters the legal landscape for retailers and consumers. Critically, it prohibits any person, including retailers, from selling, offering to sell, or transferring an unfinished frame or receiver unless it has been serialized by a federal licensee. This means that as of July 1, 2024, the sale of unserialized “80% lowers” or polymer frames to California residents is generally unlawful. The statute also requires that any such serialized component be processed through a licensed dealer with a completed DROS (Dealer’s Record of Sale) and a background check, just like a complete firearm. This aligns the transfer process for these components with that of finished firearms.
SB-118: Mandatory FFL Serialization Services
SB-118 (Stats. 2023, ch. 293) complements AB-1089 by requiring that any person licensed as a dealer under California law must offer and provide serialization services. Effective January 1, 2025, a dealer must, upon request, engrave a unique serial number issued by the CA DOJ onto an unfinished frame or receiver or a firearm manufactured or assembled by a person. The dealer must follow specific federal and state marking requirements and record the serial number in their bound book. This statute ensures that individuals have a mandated pathway to comply with serialization laws through established FFLs. For broader federal context on firearm commerce, see our federal law guide.
What You CAN Do Under Current California Law
Despite the restrictive laws, certain activities remain lawful for individuals who are not prohibited from possessing firearms.
- Build a Firearm for Personal Use: You may still manufacture a firearm for personal use, but it must be serialized through the CA DOJ process before it is completed, and you must be eligible to possess firearms.
- Apply for a CA DOJ Serial Number: You can apply to the CA DOJ for a unique serial number, pay the required fee, and then have it engraved on your unfinished frame or receiver before completing the manufacturing or assembly process.
- Use an FFL for Serialization: You can utilize a California-licensed dealer’s serialization services, as required by SB-118, to have your serial number applied.
- Possess Grandfathered Firearms: Firearms built for personal use and serialized with a CA DOJ-issued number prior to July 1, 2024, are generally grandfathered and lawful to possess, provided they were made in compliance with the law at that time.
- Purchase Serialized Components from an FFL: You can legally purchase an unfinished frame or receiver that has been serialized by a federal licensee, provided the transfer is processed through a California dealer with a background check (DROS).
What You CANNOT Do Under Current California Law
The statutes explicitly prohibit several activities related to unserialized components and unregulated manufacturing.
- Sell or Transfer Unserialized “80% Lowers”: As of July 1, 2024, you cannot sell, offer for sale, or transfer an unfinished frame or receiver that lacks a serial number applied by a federal licensee (Pen. Code u00a7 30412(a)).
- Purchase Unserialized Kits or Components: You cannot legally purchase an unserialized polymer frame or 80% lower receiver kit shipped directly to you in California after the effective date of AB-1089.
- Build an Unserialized “Ghost Gun”: You cannot manufacture or assemble a firearm without first obtaining and engraving a serial number from the CA DOJ (Pen. Code u00a7 29180(b)).
- Sell a Personally Manufactured Firearm: You cannot sell or transfer a firearm you built for personal use unless you first have it serialized by an FFL and transfer it through an FFL, with limited exceptions (Pen. Code u00a7 29180(i)).
- Manufacture for Sale Without a License: You cannot engage in the business of manufacturing firearms for sale without appropriate federal and state licenses.
The CA DOJ Serial Number Application & Engraving Process
For individuals building a firearm for personal use, compliance centers on the state’s serialization process. First, you must apply to the CA DOJ for a unique serial number using the required form, which includes a fee and a personal eligibility check. Upon approval, you receive the serial number. This number must then be engraved onto the unfinished frame or receiver before you complete the manufacturing or assembly process. The engraving must meet specific depth, size, and placement requirements as outlined in the application instructions. Finally, you must submit a completion form to the DOJ. Failure to follow this sequence is a violation of law.
FFL Requirements, Roster Implications, and Common Mistakes
Federal Firearms Licensees (FFLs) in California have new obligations under SB-118 to provide serialization services. The firearm roster (Pen. Code u00a7 32000) does not apply to the sale of a serialized unfinished frame or receiver, as it is not a complete, operable handgun. However, if the completed firearm is a pistol, its configuration may still be subject to other laws like the assault weapon ban. Common compliance mistakes include attempting to build a firearm before receiving the DOJ serial number, improperly engraving the number, failing to submit the completion form, or assuming a personally built firearm can be freely sold. Retailers must ensure they only ship compliant, pre-serialized products to California. For state-specific shipping information, use our state shipping guide.
| Statute / Requirement | Effective Date | Key Provision | Relevant Code Section |
|---|---|---|---|
| AB-1089 (Sales Ban) | July 1, 2024 | Prohibits sale/transfer of unserialized unfinished frames/receivers. | Penal Code u00a7 30412 |
| SB-118 (FFL Service) | January 1, 2025 | Requires CA dealers to offer serialization engraving services. | Penal Code u00a7 29182 |
| Unserialized Firearm Act | Prior Law (Amended) | Establishes DOJ serial number application process for personal builds. | Penal Code u00a7u00a7 29180-29184 |
| Personal Manufacturing | Ongoing | Allowed only with a CA DOJ-issued serial number applied prior to completion. | Penal Code u00a7 29180(b) |
| Grandfathering | July 1, 2024 | Firearms serialized per state law prior to 7/1/2024 are generally lawful to keep. | Penal Code u00a7 29180 note |
Frequently Asked Questions (FAQ)
Is it still legal to build a gun from an 80% lower in California in 2026?
Yes, but only under strict conditions. You must first apply to and receive a unique serial number from the California DOJ, engrave it onto the unfinished receiver, and only then complete the build. The firearm is for personal use only and cannot be built with the intent to sell.
Can I buy a Polymer80 frame or 80% lower kit in California now?
You can only purchase a Polymer80 frame or similar unfinished receiver if it has been serialized by a federal licensee (like an FFL manufacturer) and the transfer is processed through a California firearms dealer with a background check (DROS). Direct sales of unserialized kits to consumers are prohibited under AB-1089.
What is the penalty for possessing an unserialized “ghost gun” in California?
Under Penal Code section 29180, possession of an unserialized firearm that is required to be serialized is generally punishable as a misdemeanor or a felony, depending on the circumstances and the individual’s criminal history. The statutes prescribe specific penalties for violations.
I built a firearm years ago. Do I need to serialize it now?
If you manufactured a firearm for personal use and applied for and engraved a CA DOJ-issued serial number on it prior to July 1, 2024, it is generally considered grandfathered. If you never serialized it, you may be in violation of the law and should consult the CA DOJ or legal counsel for guidance on potential compliance options. Laws in other states vary; for example, see our guides on New York and Washington laws.
Can an FFL refuse to serialize my firearm or lower?
Beginning January 1, 2025, SB-118 requires California-licensed dealers to provide serialization services. However, they may refuse service if you cannot provide proof of eligibility, if the item is contraband, or if engraving the item would violate other laws. They are also permitted to charge a reasonable fee for this service.
Does California’s handgun roster apply to 80% lowers?
No. The Unsafe Handgun Act (roster) applies to complete, operable handguns. A serialized unfinished frame or receiver is not a complete firearm and therefore is not subject to the roster requirements at the point of sale. However, the finished firearm must still comply with all other applicable laws, such as those regulating assault weapons.
How do California laws compare to other states?
California’s laws are among the most comprehensive. Other states like New York and Washington have also enacted strict regulations, while states like Texas and Florida have different legal frameworks. It is crucial to understand the laws of your specific state. You can compare by reviewing our pages on Texas and Florida regulations.
Navigating California’s complex regulations on unfinished frames and receivers requires careful attention to the effective dates and specific requirements of AB-1089, SB-118, and the Unserialized Firearm Act. Compliance hinges on understanding the legal pathways for serialization through the CA DOJ and licensed dealers, and knowing the clear boundaries on sales and personal manufacturing. For consumers, this means ensuring any purchase or build follows the statutory sequence. Retailers must adapt their practices to ship only compliant, pre-serialized products. Always refer to the actual statutes and official CA DOJ guidance for the most current information. To explore compliant products available for shipment to California, visit our online shop.