I think the issue is ATF is looking at solvent traps like 80s. You and I and they know the things are intended to be made in to silencers (hopefully after you have a form 1 done and stamp in hand!)
But as for what the NFA says, that makes them suppressor parts. Even if it isn’t functional yet. And that makes the solvent trap maker the manufacturer. And for a suppressor, you can’t be the maker of a can from already NFA parts. You’d need an FFL/SOT to do that.
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You’d need to build one from scratch or from parts not intended to be part of a silencer. Get a form 1 and get a maglight and some actual automotive freeze plugs and a former I guess. Or actually mill things from bar stock or similar.
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I have seen several screen shots posted of alleged emails with ATF about this. Apparently they are planning to start requiring parts lists, pics, and diagrams for form 1 applications to insure you are not making them from kits. If so why not announce that first before just randomly denying applications.
I also don't understand why it really matters how it's built, it is still registered with a tax stamp, same as if you purchased one already complete. I can almost understand why they are going after the kit manufacturers, I don't agree with it but can see some logic to it at least. I know, I know, logic doesn't exist within the ATF. I wonder how much time effort and money is going into enforcing this new 'rule" and how it gonna stop crime or make anyone safer? That is the purpose of the ATF isn't it?
Fudd Busters will be covering this at 11am today
Every hardware and auto parts store is chock full of suppressor components .
"Pictures of the parts you will use to make the silencer"
Dare I say "entrapment"? 5th Amendment violation?
couldn't agree more.
While I don't expect too much, but here was my response to them. Hopefully going the extra mile to appease these worthless POSs at the ATF with pictures of the equipment I have will move this crap along as it is... Well everyone knows what it is.
Hope this works out for you, I got the same notification but now considering abandoning this venture, and getting a refund.
I think ATF is miffed that they can't get a tax stamp price increase approved and $200 isn't the obstacle it once was. Add in relatively inexpensive solvent traps, which look kind of like 80% suppressors, and too many people are joining the NFA club (in ATF's opinion.)
If the Republican AGs can't put ATF back in the box on solvent traps, I hope the US solvent trap manufacturers that ATF is hassling get the appropriate FFL to start making cheap suppressors. That should increase competition and drive down prices as well as frosting ATF's ass.
It seems to me that one could submit whatever they want to hear and they do whatever they want to do and there is nothing the ATF can do about it. The stamp is for a Silencer, not a process or raw material. This is just more BS and we need an organization like the ACLU that will sue EVERY time they do something like this.
What if you change your process or material? There is no law or requirement to tell them.