per atf.gov:
National Firearms Act Definitions
Silencer
26 U.S.C. § 5845(a)(7)
For the purposes of the National Firearms Act the term Silencer is defined in 18 U.S.C. § 921(a)(24)
"The term “Firearm Silencer” or “Firearm Muffler” means any device for silencing, muffling, or diminishing the report of a portable firearm, including any combination of parts, designed or redesigned, and intended for the use in assembling or fabricating a firearm silencer or firearm muffler, any part intended only for use in such assembly or fabrication."
ATF could probably argue that the piston in each round of loaded ammunition constituted a "Silencer" and would require registration and a tax stamp for each round of ammunition. However, possibly not the firearm itself separate from its ammunition.
They certainly could classify the ammunition as AP under "The Violent Crime and Law Enforcement Act of 1994".
Although, it could also be argued that Aguila Super Colibri .22LR ammunition is technically a combination of parts "intended" to "[diminish] the report of a portable firearm".
Of course trying to "guess" how ATF would interpret this design for manufacture or import is like trying to guess the winning lottery numbers.