Reports of Mass Disapprovals of eForm 1 Silencers

[atblis]

Additive manufacturing for metal parts at home…

 

[IMBLITZVT]

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.
.....
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.
...

I don't think this logic holds. If you make steel for Suppressors, are the raw materials regulated. Does the company Silencerco buys AL from need a FFL because we know the AL they buy will go into a suppressor and so is unregistered suppressor parts that are not complete? If you are going to make solid cylinder of steel into the outside of a suppressor, is the cylinder of metal a suppressor? If you have a tube of steel that will be made into a suppressor? Until its a 100% finished part, it is a suppressor part? I mean even the unofficial 80% rule on receivers is out there to clear this up for receivers. Can you have the parts 80% done, 10% done, just a pile of metal when it comes to suppressors?

Just the basic law on 100% suppressor parts does not make sense. I take a normal store bought suppressor. I take it apart for cleaning. NOW ever baffle is an illegal unregistered Suppressor part as its not in the registered tube any more! The end cap is a suppressor part too! I mean thats why we can't have wipes anymore!

I don't think this would hold in court as the logic is not there.

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?

First, asking for logic is not something you can do with ATF. Next, who at ATF knows anything about drawings! Who would know what they are looking at there! Sounds like more BS just to make people stop applying. Like the solvent trap people can't supply the drawings...

I guess they are out to stop ghost suppressors! Oh boy!

You know what they will get in the end... a bunch of solvent traps floating around looking to be illegally converted because you can't do so legally.

 

[Biggfoot44]

Every hardware and auto parts store is chock full of suppressor components .

 

[DC-W]

Fudd Busters will be covering this at 11am today

A good watch, but yikes.

 

[teratos]

Every hardware and auto parts store is chock full of suppressor components .

Damned right. WIX filters and freeze plugs.

They are full of firearms, too.

 

[theNOTORIOUSmo]

Just got this in my email... asking for proof as to how I will make it.

Going to send them links to various metal sites online as to where I will purchase it and a picture of my cnc mill and manual lathe with my name and date on a paper place on it as to how I will make it.

Complete crap that I have to jump through all these hoops to pay a tax to make something.

 

[Mike OTDP]

"Pictures of the parts you will use to make the silencer"

Dare I say "entrapment"? 5th Amendment violation?

 

[magnumpi]

View attachment 336128

A pic of parts to send them

 

[Growler215]

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.

 

[theNOTORIOUSmo]

"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.



Pictures of the parts that you will use to make the silencer (the pictures should be clear and allow the identification of the parts photographed):

- No "parts" have been purchased yet. Raw material will be purchased through various online and local retailers based on price / availability and will be dependent on approval of the form 1

A description of the processes you will use to assemble or fabricate the silencer.:

-Attached in the pictures in this email are a picture of my lathe and CNC converted mill. included on each piece of machinery is my hand written name with the date to verify that I do in fact own these machines. While I may not be a machinist by trade, also attached is a picture of my degree in mechanical engineering verifying that I have the knowledge to create all parts and fabricate them.

-The process will entail obtaining a titanium or stainless tube (depending on current price and availability) and using the lathe to line bore the tube concentric.

-Individual baffles will be made from titanium and/or stainless bar stock (depending on price and availability) and turned first on the lathe and/or cnc mill turned (depending on complexity)

The source from which the parts were obtained, i.e., the name of the store, website, etc.:

-No "parts" have been purchased yet. Raw material will be purchased through various online and local retailers based on price / availability and will be dependent on approval of the form 1. Some examples of potential stores will be "onlinemetals.com" , "racetechtitanium.com" , Metal supermarket Baltimore (local supplier), and Access Metals (local supplier)

 

[Trigger Time]

They want to know where you bought the parts to make it ? They want you to tell them who they will raid next.

 

[rbird7282]

This is a bunch of BS. This is what happens when regulatory agencies have no checks on them.
If they can say a block of aluminum or titanium is a suppressor part, the agency simply needs to go away.
This reminds me of DC saying and empty spent shotgun shell is ammunition.
These people have all escaped from the asylum.

 

[chino101]

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.

 

[traveller]

Hope this works out for you, I got the same notification but now considering abandoning this venture, and getting a refund.

There is some history on which parts the ATF considers the key components of the silencer. If a manufacturer buys those parts from another manufacturer, that second manufacturer or machine shop has to be approved and there has to be accountability for the parts. Unless you have those components as pre-made parts in your parts-list, you are going to be ok.

I dont think the open ended 'various parts bought from various online retailers' explanation is going to fly.

Tell them 'I am planning to buy 28mm titanium x/y/z tube and multiple discs of x/y/z titanium from somethingtheothermetals.com. I have access to a machine shop equipped to machine those pieces into the components required for the suppressor specified in my form1 submission. Give them item numbers from the metal dealer for the raw materials you are planning to buy.

Unless of course your intent was to buy a parts-kit that only requires some minor drilling, assembly and finish work. Then yes, you are probably better off getting a refund.

 

[Doctor_M]

Send them a picture of the soda bottle isle from the local grocery store.

 

[IMBLITZVT]

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.

Oh the bright side, whoever was doing form 1s just got mine bumped up by about 8 months! Form 1 a MG should not be touched by this! So its just me and the SBR people now!

 

[Squaregrouper]

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.

I agree with this theory. $200 was a lot of money when NFA was enacted.

 

[Mike OTDP]

I'm not in the home-brewed suppressor game, my only interest is purely academic...or would be, if I were working on a doctoral thesis in Aerospace Engineering (Heat Transfer Predictions for Non-Steady-State, Highly Turbulent Flow). This is partly Congress' fault - they passed the law that defined suppressor components as a suppressor. At the same time, ATF is behaving irresponsibly. Anyone who has filed a Form 1 is making a good-faith effort to comply with the National Firearms Act. You don't worry about them.

Although this is like 80% receivers...who in their right mind would buy one, except cash-and-carry at a gun show not in their area?

 

[traveller]

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.

True, but you can't lie on a .gov form, even if it is inconsequential. If you intentionally lie on a tax return, even if you give the IRS extra money because of it, you can run into trouble.

They dont care how your silencer looks like in the end. They care that you didn't use parts they deem 'illegal' at the time you incorporated them into the silencer.

And just like anything else, they dont actively go out and enforce this. Just like they dont enforce just how long the barrel on your SBR is, but if you push it in their face that you did something different from what they approved, you may force them to act.

And you know that someone is going to go to the federal pen over this form1 boondoggle. And I can tell you how its gonna go down. The technical term is 'aggravated dumphuckery' and involves the use of the book of faces, insta-dumb and Youtube. Someone will send in a form1 stating that he is going to whittle all the parts from a solid block of titanium and get his form approved. Then he will go on what they call 'social media' and post a video that says 'neh-ne-ne-neeh-neh, I got one over on the ATF. Look at my suppressor here, because they have no way of finding out, see, I told them I'll make it myself, but then I went online and ordered this 'barrel-shroud' from JimBobs barrelshroudery in Bumblefork, WV, but you see, its really a complete silencer tube assembly. All I had to do was to turn it around and punch that little tab out here and screw in a threaded adapter that JimBob mailed me. Then I bought those baffles from JimBob and stuck it all together and Wah-laah, I have myself a suppressor. Easy-peezy, the ATF is so dumb, neh-neh-neh-nee-neh.'
And not only is JimBob and his machine shop gonna get raided, the DP himself is going to have some uncomfortable conversations with his attorney and the AUSA on just how many of their counts he is going to plead guilty to.

If you write you are going to do X, then do X, or something that looks like X.

 

[Alea Jacta Est]

I’m back to tyranny…