PC 29180:
Ghost Gun Serialization

California Penal Code Section 29180 ^[1] requires that any person who manufactures or assembles a firearm must apply to the California Department of Justice for a unique serial number or other mark of identification before completing the manufacturing or assembly process. California was the first state to enact this type of requirement, beginning with AB 857 in 2016. Since then, the legislature has significantly expanded the regulatory framework surrounding ghost guns and their component parts.

Application Process

Before manufacturing or assembling a firearm, the person must:

• Apply to the DOJ through the California Firearms Application Reporting System (CFARS) ^[2]
• Provide personal identifying information and undergo a background check
• Describe the type of firearm to be manufactured (handgun, rifle, or shotgun)
• Receive a unique serial number assigned by the DOJ
• Engrave or permanently affix the assigned serial number on the firearm in a manner prescribed by regulation

Engraving Requirements

The serial number must be engraved or permanently affixed on the firearm in compliance with specific technical standards:

• The serial number must be placed on the frame or receiver
• Characters must be engraved to a minimum depth of .003 inch and be at least 1/16 inch high
• The engraving must be in a conspicuous location on the firearm
• The serial number must not be susceptible to being readily obliterated, altered, or removed

Prohibition on Transfer

A self-manufactured firearm may not be sold or transferred to any other person. Under Penal Code Section 29180(d) ^[3], a person who manufactures or assembles a firearm for personal use may not sell, offer for sale, assign, pledge, lease, give, lend, or otherwise transfer that firearm without first having a licensed manufacturer apply a licensed manufacturer's serial number to the weapon and process the transfer through a licensed dealer.

AB 1263: Expanded Accessories and Ghost Gun Regulation (Effective January 1, 2026)

AB 1263 ^[4] significantly expanded the regulation of firearm accessories and ghost gun components. The law broadens the definition of "firearm accessories" under the Firearm Industry Responsibility Act (FIRA) to include any other device, tool, kit, part, or parts set that is "clearly designed and intended for use in manufacturing firearms." These newly regulated accessories include pistol grips, thumbhole stocks, folding or telescoping stocks, flash suppressors, forward pistol grips, threaded handgun barrels, second handgrips, and handgun shrouds.

Key requirements under AB 1263 include:

• Age verification and ID matching: For nonexempt sales and deliveries of firearm barrels, firearm accessories, or firearm manufacturing machines in California or to California residents, the purchaser must provide proof of being at least 18 and proof of identity, the shipping address must match that identification, and the purchaser must present identification and sign at delivery
• Adult signature required: A purchaser aged 18 years or older must present identification and sign for delivery of firearm accessories, subject to the specified recipient and carrier exceptions
• Prohibition on digital manufacturing files: AB 1263 authorizes civil actions against a person who knowingly distributes CAD or other digital manufacturing instructions for CNC machines or 3D printers that can produce firearms, firearm accessories, barrels, or large-capacity magazines to a person in California who is not a federally licensed firearms manufacturer. Exceptions cover members of the military or National Guard while on duty and acting within the scope and course of employment, law enforcement agencies, and forensic laboratories
• Expanded civil liability: The law extends civil liability under FIRA to cover the newly defined accessory categories

The California Attorney General released an informational bulletin ^[5] outlining compliance obligations for retailers and distributors.

SB 704: Firearm Barrel Sales Through Dealers (Effective January 1, 2026)

SB 704 ^[6] adds a new layer of regulation targeting standalone firearm barrel sales, recognizing that barrels are a critical component in ghost gun manufacturing. The law defines "firearm barrel" broadly to include partially finished barrels that can be "readily completed."

SB 704 has a two-phase implementation:

• Phase 1 (January 1, 2026): Except for transactions exempted by the statute, standalone firearm barrel sales or transfers must be completed in person by a California-licensed firearms dealer. Barrels may not be shipped directly to nonexempt California purchasers. A first or second violation of the sale, transfer, or offer-to-sell restrictions is a misdemeanor. A third or subsequent violation may be punished as a misdemeanor or felony.
• Phase 2 (July 1, 2027): Except for transactions exempted by the statute, dealers must conduct an eligibility check in the manner prescribed by DOJ and electronically report barrel sales and transfers to DOJ. The initial eligibility check fee is up to $5 and may not exceed DOJ processing costs. DOJ may increase the fee each year by up to $1 as necessary to reimburse its eligibility check costs.

Federal Law: Bondi v. VanDerStok (March 2025)

On March 26, 2025, the U.S. Supreme Court issued a 7-2 decision in Bondi v. VanDerStok ^[7] (originally styled Garland v. VanDerStok), upholding the ATF's 2022 final rule classifying weapons parts kits and unfinished frames and receivers as "firearms" under the Gun Control Act of 1968. Justice Gorsuch wrote for the majority, concluding that at least some weapons parts kits fall within the statutory definition of "firearm" and that the ATF rule is a permissible interpretation of the statute.

The decision reinforces the federal serialization requirements for commercially produced frames, receivers, and parts kits. California's state-level requirements under Section 29180 are broader than the federal rule because they apply to personally manufactured firearms regardless of how the frame or receiver was acquired, and they require prior DOJ approval before manufacturing begins.

Penalties

Violation of Section 29180 is a misdemeanor. Manufacturing or assembling a firearm without first obtaining a serial number from the DOJ is punishable by imprisonment in a county jail for up to one year, a fine of up to $1,000, or both. Possession of an unserialized firearm manufactured after the effective date may also result in charges under other provisions of the Penal Code, including Section 23920 ^[8], which prohibits knowing possession of firearms without a valid state or federal serial number or identification mark and specified transactions involving firearms known to have changed, altered, removed, or obliterated identifying marks, subject to the exceptions in Section 23925.