Read this on ATF's site:

Marking, Registration, and Transfer Requirements for Silencers
Under the proposed rule, a “frame or receiver” of a firearm muffler or silencer device is defined as a housing or holding structure for one or more essential internal components of the device, including, but not limited to, baffles, baffling material, or expansion chamber.

Manufacturers and makers of complete muffler or silencer devices need only mark each part (or specific part(s) previously determined by ATF) of the device defined as a “frame or receiver” under this rule. However, individual muffler or silencer parts must be marked if they are disposed of separately from a complete device unless transferred by qualified manufacturers to other qualified licensees for the manufacture or repair of complete devices.

A qualified manufacturer may:

Transfer a silencer part to another qualified manufacturer without immediately identifying or registering such part provided that, upon receipt, it is actively used to manufacture a complete muffler or silencer device.

Transfer a replacement silencer part other than a frame or receiver to a qualified manufacturer or dealer without identifying or registering such part provided that, upon receipt, it is actively used to repair a complete muffler or silencer device that was previously identified and registered in accordance with this part.
Persons may temporarily convey a lawfully possessed NFA firearm, including a silencer, to a qualified manufacturer or dealer for the sole purpose of repair, identification, evaluation, research, testing, or calibration, and return to the same lawful possessor without additional identification or registration.

Oh boy. Form 1 cans are going away.

I didn't get that, from what was posted, at all.

Silencers should be unregulated, and required.

Americans should be able to buy them at 7-11 and they should be on rack hangers beside the crack pipes.

Right below the brand new M16s and bottles of Jim Beam,

And I am not being sarcastic.  

Just read this on Ammoland:

Homemade suppressors will take a hit under the proposed rules. The tube itself will become the suppressor. The ATF has recently cracked down on Form 1 silencers. The government, law enforcement agency paused 3000 eForm submissions. Out of those 3000 submissions, 850 were denied by the ATF. The agency said the builder used parts that are already silencers. These included parts that the Bureau has always said were not regulated by the NFA.
The law enforcement agency also requested that the makers submit pictures of all parts used in the build, list how they plan on building the suppressor, and list where they acquired the parts. This request for information is a break from previous policies, which only required caliber and length.

The ATF was expected to give dealers and manufacturers 90 days to comply with the new regulations. Inside sources report that the time frame has shrunk to 60 days. The ATF and the Whitehouse didn’t respond to AmmoLand New’s request for comment.
Follow us: @Ammoland on Twitter | Ammoland on Facebook

https://www.atf.gov/rules-and-regulations/definition-frame-or-receiver/summary

Misread

More news:
https://www.gunowners.com/8-general/247-gof-to-release-atf-s-secret-solvent-trap-technical-bulletins
https://www.gunowners.org/20-senators-demand-accountability-from-atf-on-solvent-traps-frts-referencing-goa-leaks-foia-documents/?fbclid=IwAR3Eoa6CJy6RRq3VKp_Qn_CL-Za-FwFl_IY6kQpPCKnEWKqWlTa-oEPsiWQ

For Immediate Release

Springfield, VA—On Friday twenty senators sent a letter directly to Attorney General Merrick Garland and the Acting Director of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) Marvin Richardson demanding accountability for its “incredibly troubling […] pattern of secret regulation” and for making “blanket threats” for “possessing various firearms accessories, none of which are illegal based on any statute or regulation.”

Gun Owners of America first broke the news that the ATF was “ordering [the] seizure of various items and referring to those in possession as ‘defendants’” in January on an episode of The Minuteman Moment entitled ATF LEAK: Trigger Confiscation (and MORE) Incoming.

Through documents leaked by the Gun Owners Foundation, GOA was also able to provide internal ATF technical bulletins to the senators which shed light on the ATF’s long and malicious history of secret guidance documents:

Disturbingly, ATF made these documents available only to those tasked with enforcing the law, rather than those who strive to comply with it.  Indeed, ATF marked these documents as ‘Law Enforcement Sensitive’ to conceal them from the firearms industry and the American public.

These internal tech bulletins were published on the Gun Owners Foundation website today.

Aidan Johnston, Director of Federal Affairs for Gun Owners of America said: “GOA is proud to see Senators standing up to the ATF on behalf of solvent trap and semi-automatic trigger owners.” Johnston continued, “Using secret guidance to confiscate firearm accessories and criminally prosecute gun owners constitutes an un-American infringement on the right to keep and bear arms.”

–GOA–

I love how you can leagally spread aids willingly to hundreds of people. But god forbid you make your firearm not make your ears bleed.

I am going to call this the quiet bore exemption. They have the ffl ( I think they have the ffl ) to sell marked tubes and parts, so they are a qualified manufacturer. The loop hole to use against the atf, is an approved form 1 makes you a qualified manufacturer. So a qualified manufacturer can sell you a kit ( via form 4 ), as long as the tube is marked and it only contains the parts for the silencer, or no parts just the tube. or see the next part.

The fun part is the second part above. It states a qualified manufacture may transfer to another qualified manufacture, and an approved form one makes you a qualified manufacturer ( does not say licensee on this part ) as long as the part is immediately used to make a silencer.  So Example, you file for a form 1, and it gets approved. You then cut an 8 inch long piece of ti tube and serialize it, It is now a legal form 1 suppressor. You could then order cups that are drilled ( or not ) from another qualified manufacturer and put them in your serialized tube, upon receipt you need to actively use the parts, ie no sitting a shelf for 6 months.. Then you assemble and weld shut ( no tools needed to thread the tube ) or even send it to some like ecco for threading.

It is what the wording says

Your understanding vs. afts understanding.

YMMV

No, it's not.

There's an important legal distinction between a licensed manufacturer and a form 1 maker.

It's dumb, and none of this should be regulated, but thems the rulez.

@StaccatoC2
A Maker and a Manufacturer are 2 completely different statuses.
A manufacturer has a license to make firearms and completes a 5320.2 (Form2) for these.
A maker is unlicensed and must complete a 5320.1 (form1) for their NFA makes.

Manufacturer



Maker

But is not how the batfe will apply it.  In a Q&A an agent said you could buy a 6 foot pipe from Home Depot for your form 1, but if you cut a 6" piece off, or are left with a chunk after using the rest for a project, you could be in legal jeopardy from the "aft".

They also stated in the legal speak at the bottom of the new form 1 app on their website that only the maker can machine the parts, and that having a form 1 did not allow one to have someone else make parts or the entire suppressor, and that having a form 1 did not allow you to purchase a premade suppressor (a solvent trap)...

They will read it however they want, that is why they are literally rewriting the law and redefining suppressor, receiver, firearm, rifle, and more in this rule, totally usurping the authority of the legislature.

It is unlawful and unconstitutional.

Atf solvent traps doc internal

Here is the legal speak I referred to on the form 1...

https://www.ar15.com/forums/general/ATF-Mass-rejection-of-Form-1-silencer-apps-/5-2534357/

I think a lot of people here just need to understand that the AFT is going to do whatever the hell they think they can get away with, and that the consistency, legality, and constitutionality of any given pronouncement they put out is irrelevant - and that nobody is going to hold them to following any of those requirements.

We live in a post-legal world and people need to deal with it.  You have to assume that they won't just yank the rug out from under you, but that they will go out of their way to make opportunities to do so.

Another Bend Over from the Firearms Owners Protection Act.

Found more, also included ATF internal guidelines on solvent traps.

https://www.gunowners.com/8-general/247-gof-to-release-atf-s-secret-solvent-trap-technical-bulletins

This one is on Bump Stocks petition the GOA has sent to the United States Supreme Coart.

https://www.gunowners.org/goa-files-petition-supreme-court-bump-stock-ban/

This one is bills being introduced to repeal the NFA in pieces.

https://www.gunowners.org/goa-backed-bills-repeal-sbr-sbs-aow-regulations/

So, by the ATF's own document, solvent traps are legal and have a use other than as a silencer.
Center marks (on the front cap) are verboten and the ATF could've just said this openly. Sounds like they let it continue to the current point.
Also, it only states center marks on the front cap and not on internal cups...

Apparently, even if you are making from scratch, you will be denied. I was with no reason given other than "Disapproved, Other". It was approved, then two minutes later disapproved, no reason given.

Got a call from a NFAD supervisor and was invited to resubmit the Form 1 and send it to their desk. Maybe an approved one this time.

I watched this last night, it doesn't look good for the gun owners.

https://www.youtube.com/watch?v=z8OFMVFGW2A

I got a letter from one of my Senators today.. At least its not a form "but think of the children" letter.  Sounds like he is actually opposed to the AFT's jack-booted antics.

part 1/3

part 2/3

part 3/3

The atf are terrorists and need gone

It appears the ATF is refusing to answer the requests the Senators and Congressmen have submitted in their letters, go figure. I guess they are above answering the legislative branch of the government because they make the rules, look at bump stocks, a piece of plastic attached to the outside of the gun is a machinegun.
Now after 10 August 2022 a piece of pipe is a suppressor, if a piece of metal in the ATF's opinion looks like a receiver or a frame, it is a frame or receiver. Alot of non-firing reenactment guns are at risk of being caught up
in this, starter pistol are considered to be firearms because they are readily convertible to fire a projectable.  All the starter pistols I have seen had solid barrels with a wedge in line with the chamber.

I guess people should remind the people who signed those letters that they haven’t received a response.

Will illegal aliens that can't read the AFT rulings be exempt from the rulings?