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Posted: 4/17/2008 8:37:52 AM EDT
[#1]
Never mind, I see it is hosted on the ATF web site. |
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Posted: 4/17/2008 9:04:35 AM EDT
[#2]
haven't seen this on that silencer site yet...  |
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Posted: 4/17/2008 11:07:48 AM EDT
[#3]
Well, this is an interesting development.
~Dg84 |
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Posted: 4/17/2008 12:23:29 PM EDT
[#4]
I don't think it is a development at all, I just don't think I'm alone in thinking the tube ruling is rediculous. If the endcap is serialized, it can be replaced if damaged with a similarly marked cap. BUT NOT SO FOR THE TUBE..... WHICH is obviously dramatically different from a serialized end cap which Skirts the ruling. haha It's just a ruling that cheats users with damaged cans out of additional tax duties. Obviously the tax stamp should cover the serialized can, regardless of whether the destroyed tube is replaced with an identically serialized and marked replacement component or not. It would even make more sense if the user could then send the "beyond repair" can to the ATF, as credit for the new tax stamp for the SAME SERIAL NUMBER. Anything else is just fishing for money on a bill that has already been paid. I mean from what I read they are suggesting people get new stamps for the same serial in the event of damaged tubes in need of replacement. |
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Posted: 4/17/2008 1:16:44 PM EDT
[#5]
So, what you're saying Green0 is one manufacturer can't "repair/rebuild" another manufacturer's silencer by simply stamping a new can with all the info and serial number from the old can? That's what I find interesting... In the end I agree, it's the customer that gets the shaft. ~Dg84 |
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Posted: 4/17/2008 1:22:27 PM EDT
[#6]
I think they are saying NO-one. Not even the original manufacturer can repair such a product, but can only replace it with an entirely new unit, on the same serial, and re-conduct the taxed transfer for another $200 stamp on the same serial #. It's the new transfer of the essentially same product to the same person that seems contradictory and flawed. |
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Posted: 4/17/2008 1:31:13 PM EDT
[#7]
Roger... ~Dg84 |
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Posted: 4/17/2008 1:33:41 PM EDT
[#8]
Maybe I am missing something but, I don't see the point of having to pay another $200 tax to replace the tube other than a way to collect another $200.
I could see if they were trying to prevent having two suppressors with the same serial number but It doesn't say anything about having to prove that the original tube was destroyed. I guess it just removes the incentive of trying to get away with owning two suppressors with the same serial number and only one tax stamp ?? |
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Posted: 4/17/2008 3:28:17 PM EDT
[#9]
So who
 did ALL owners of a can "this nice favor " by asking atf for a letter like that  who has the greatest benefit of that letter That is really "a nice customer service ",,now people has to pay $200 extra for a repair  |
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Posted: 4/17/2008 4:15:26 PM EDT
[#10]
It would be interesting to know who asked for this letter.
So basically because of this if some malfunction destroys my suppressor I will be out $200?
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Posted: 4/17/2008 4:21:02 PM EDT
[#11]
The cost of the repair PLUS $200. |
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Posted: 4/17/2008 4:30:36 PM EDT
[#12]
well from now on the manufactures should put the serial number on the mounting endcap
just to make sure the customer later can have the can repaired without paying the extra pirat tax ,,,, easy enough those who dont ,,,would take away this option from the customer |
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Posted: 4/17/2008 4:31:44 PM EDT
[#13]
Actually, it sounds like lifetime warranties just got a lot more expensive for suppressors manufacturers.
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Posted: 4/17/2008 4:31:45 PM EDT
[#14]
ps who needs anti gunners ,,when some force trough a letter like that
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Posted: 4/17/2008 4:32:15 PM EDT
[#15]
Someone must have written a letter requesting a ruling.... is Eric Larson lurking around? |
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Posted: 4/17/2008 4:39:12 PM EDT
[#16]
Oh Joy.
Someone prodded the ATF till they issued anothe rarbitrary ruling that makes our collective lives suck just a little bit more. I quote from the ATF .pdf ----------------------------- Repairs may not be done if they result in removal, obliteration, or alteration of the serial number, The replacement of the outer tube is so significant an event that it amounts to the "making" of a new silencer. Increasing the length of the outer tube significantly affects the performance of the silencer and results in the "making" of a new silencer. A damaged outer tube may be repaired by any Federal firearms licensee qualified to perform gunsmithing or by the registered owner. ... The repair may not be performed if it results in the removal, obliteration, or alteration of the serial number, Q4: If the outer tube is destroyed or damaged beyond repair, may it be replaced? A: Unless the outer tube is replaced by the manufacturer prior to its removal from the manufacturing premises for purposes of sale or distribution (see Q6), the replacement of the outer tube amounts to the making of a new silencer. ----------------------------- So, if you have a tube that has suffered wall damage, you're SOL to the tune of no less than $200 PLUS any costs and hassles related to getting another F4 approved. All that is over and above any repair cost the manufacturer might charge. I guess this means I'll have to buy the heaviest duty, military grade cans I can from here on out. |
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Posted: 4/17/2008 4:42:26 PM EDT
[#17]
They cover such logical steps too... ----------------------------- ATF strongly recommends that manufacturers place all required markings on the outer tube of the silencer, as this is the accepted industry standard. Moreover, this practice eliminates the need to remark in the event an end cap bearing the markings is damaged and requires replacement. Repairs may not be done if they result in removal, obliteration, or alteration of the serial number, ----------------------------- |
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Posted: 4/17/2008 4:46:57 PM EDT
[#18]
The FAQ seems to apply to worn or damaged components. What's up with basically changing a new can (nothing worn or damaged) to another manufacturers baffle stack because the customer bought a loud can and doesn't like it? Do you think this FAQ applies to that circumstance?
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Posted: 4/17/2008 4:49:16 PM EDT
[#19]
The ATF and their unknown partners in screwing us ARE magnanimous despots... they allow ONE option of modifying the tube pursuant to a repair.
Towards the end, they also show us that they are experts in the design and assembly of suppressors by stating that all the original parts can be used in a tube that is now shorter. Color me confused if you will, but I can understand how 5 pounds of fecal matter can fit in a 10 pound bag, but I'm a little shy on how you can make 5 pounds fit in a bag any smaller than 5 pounds.... ------------------------ In addition, the repair may result in a minimal reduction in the length of the outer tube due to rethreading, but repair may not increase the length of the outer tube. Increasing the length of the outer tube significantly affects the performance of the silencer and results in the "making" of a new silencer. ... Reducing the length of the tube by a minimal amount in order to repair a silencer is often necessary to replace damaged end caps, as the tube must be rethreaded. Such minimal reduction of the length of the tube uses all of the original parts, does not significantly affect performance of the silencer, and may be done as part of a repair process without making a new silencer. ------------------------ |
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Posted: 4/17/2008 4:52:15 PM EDT
[#20]
Heck - let me post the full text in the forum -- give me one minute... ------------------------ In the event that identical replacement parts for a silencer are not available, new and different component parts may be used as long as the silencer retains the same dimensions and caliber. ------------------------ |
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Posted: 4/17/2008 5:05:10 PM EDT
[#21]
Yep I sure do wonder how this all came about.
 Somebody is hurting EVERYONE just becaue they got pissed off. Thanks
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Posted: 4/17/2008 5:07:19 PM EDT
[#22]
Who/what company asked for a ruling on this? |
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Posted: 4/17/2008 5:10:21 PM EDT
[#23]
 they only recommends it ,,you dont have to ,,and working according there logic ( that for us is non understandable ) isnt needed see they use the fact that then you dont have to remark in the event an end cap bearing the markings is damaged and requires replacement. but i rather have to remark than pay $200 there logic plain sucks ,,,but what would you expect from a agency that dosnt have to pay ,,but is used to having YOU pay for every thing they do (tax money paid ) |
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Posted: 4/17/2008 5:21:13 PM EDT
[#24]
If the endcap is serialized, it may not be replaced. (see red above) This is based on the assumption that removing an end cap 'removes' the serial number from the can. Now, if you serialize a heavy duty plug in the muzzle end that has replaceable inserts for the important parts.... but, you still don't get around the prohibition on replacing the tube. You just make it much, much harder to prove. |
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Posted: 4/17/2008 5:21:31 PM EDT
[#25]
You've got to be kidding me. I can't believe people still ask the BATFE to verify things anymore. This is just another PITA to worry about in buying a silencer now.
WHO ASKED? I guarantee I will boycott any MFG that did this, if it was, in fact, a MFG. |
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Posted: 4/17/2008 5:24:19 PM EDT
[#26]
I dont know how it is in the us ,,But here in DK you can have access to papers like that,sins it Does concern everybody write the Atf and ask as a us citizen they should have everything ip address and so on it ,,its public matter ( tax money you know ) you should have the right to know ,,they for sure just did stab you( as a owner of a can) in the back This must really be a nightmare for 1928 ,if he during a test ruins a can ,,he can not have it rebuild ,,this might be the end of the( heavy duty ) testing Who ever did this letter writing really did harm the whole can community i really hope people will remember this until the back stabber is found |
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Posted: 4/17/2008 5:30:14 PM EDT
[#27]
We should just mark the serial numer on the rear, tube and front. Then a "original serial number" will always remain intact no matter what the repair.
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Posted: 4/17/2008 6:09:39 PM EDT
[#28]
I'm no fanboy... not in any respect. But I've got a good idea. At least I've narrowed down the companies I'll be dealing with in the future. Kel, thanks for posting this... ~Dg84 |
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Posted: 4/17/2008 7:01:31 PM EDT
[#29]
Think correspondence on this topic could be released under a FOIA request?
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Posted: 4/17/2008 7:11:09 PM EDT
[#30]
I like how shortening the tube doesn't seem to have an effect on it's performance, but lengthening ( even "minimal") does. You can cut it down "minimally", rethread and you're ok. 'Course, then you'll either have to machine a baffle to fit or get all new internals. But, if you cut off the end of the damaged tube, re-weld a new tube section and rethread and it's even a nanometer longer than the original you're hosed. |
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Posted: 4/17/2008 7:23:17 PM EDT
[#31]
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Posted: 4/17/2008 7:38:14 PM EDT
[#32]
Sounds like someone needs to go after the ATF.
Too bad no one has the resources. |
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Posted: 4/17/2008 7:45:06 PM EDT
[#33]
The Pope was just here, but I don't think his work visa will let him stay long enough. Other than him, who? |
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Posted: 4/17/2008 8:05:49 PM EDT
[#34]
Not surprised a CERTAIN company was involved in this.
maybe they need some cheese with their whine. we are our worst enemy. always has and always will be |
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Posted: 4/17/2008 8:05:54 PM EDT
[#35]
Did Gemtech ask for this? What a way to stir up a shit storm. If my Gemtech breaks and is found defective will Gemtech cover the cost of the stamp? BTW I don't think its wrong to ask the ATF questions, you should know that they will end up screwing you over in the end. This was a bad fucking move to say the least. If Gemtech is the one that actually ask for this I will never purchase another damn thing from them. ETA its Gemtech- Oh well I'm sure they will find other business. |
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Posted: 4/17/2008 8:28:30 PM EDT
[#36]
From what I recall, AAC got a letter saying they could replace, Gemtech got a letter saying they couldn't replace and asked for clarification. That was 2 years ago though, IIRC. Not sure if they were involved in the current declaration or not.
It really seems like someone should be able to sue over things like this. You can sue if McDonalds coffee is too hot, but not when ATF decides "changing a caliber" somehow makes it a new silencer, that's just crazy. |
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Posted: 4/17/2008 8:32:04 PM EDT
[#37]
man thats bullshit
Im not real concerned with the tax or even the bullshit of getting photos prints etc but if you get a new sheriff/ chief that is a dick you cannot get a cleo sign off and you are screwed or have to go to a trust or LLC |
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Posted: 4/17/2008 8:35:28 PM EDT
[#38]
You do realize Gemtech wrote this and Kel works for Gemtech- I betcha you're even more happy about the can purchase now.
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Posted: 4/17/2008 9:09:56 PM EDT
[#39]
I really hope that everyone here understands that Gemtech wrote this letter not for "clarification", but rather to "get back" at AAC for rebuilding and vastly improving some of their greatly lacking suppressors. Those that deny this fact or try to make excuses are either delusional or have sustained a massive head injury.
In the end, not only did Gemtech end up screwing all manufacturers, but all customers as well. |
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Posted: 4/17/2008 9:16:41 PM EDT
[#40]
Yes, and yes... ~Dg84 |
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Posted: 4/17/2008 9:19:26 PM EDT
[#41]
That is the way I am seeing it too. I don't have a dog in the gemtech vs. AAC fiasco, I don't own cans from either company. But unless there is something else behind this, I won't ever buy a can from one of those companies, and it's not hard to guess which. |
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Posted: 4/17/2008 10:37:31 PM EDT
[#42]
.edited - personal attack. Another strike aginst the american gun owner... Chalk one more up for the GOV. |
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Posted: 4/17/2008 10:39:07 PM EDT
[#43]
All,
The first I heard about this was yesterday from my attorney. He contacted me to inform me that BATFE was releasing the pdf I referenced, and to discuss the new data and how it affects the way the industry does business. This morning, the first official knowledge of this is when I received an email from BATFE telling me that this document was going public and a link to the pdf. These questions are not Gemtech's questions - they are written by BATFE legal counsel as a conglomeration of questions that have been asked by many individuals, lawyers, trade groups, and companies over a least the past ten years as an attempt to collate answers in exactly what it says it is: An FAQ. Anyone that knows their history of this industry can see these questions and answers history that started with the old Bardwell letters from 1998 (link here for original letter) that received conflicting answers, some routine manufacturers requests for clarification and procedures from more than one silencer company (For instance, Question #1 is from a company (not Gemtech) that asked over a year ago if they could serialize an internal one-piece baffle core and have various unserialized outer tubes of various colors and materials), and questions from individuals regarding the legality of services offered by some companies to them before they sent their can in for repair or modification. Gemtech has for years certainly proven that it doesn't interest us much to get involved in the kiddie games, such as the little G5 smear, the silly "which came first" arguments, etc. - we keep our heads down, do our work, and continue to make and deliver cans, not internet rivalries. This BATFE document has not been released because of any one manufacturer writing questions to the ATF for any purpose - it's come out solely because people that *do* have a habit of continually creating internet drama for their self aggrandizing and promotion have made so many loud public showings of their bending and breaking the laws that BATFE had to respond with this to clarify the questions their actions have raised. Gemtech, like every major manufacturer of firearms in the U.S., has a necessary working relationship with the BATFE. When you move millions of dollars of NFA-registered inventory each year, it is prudent to ask questions through your attorneys for guidance on how best to proceed in manners that will not expose your clients or your company to legal jeopardy. We don't ask questions that would lead to hinder our own business. If there is a questionable repair we're asked to provide, concerning our clients, we err on the side of legal caution - don't you think it would be easier (and far cheaper!) to wink at the regulations, play web-lawyer, and just make quick money from customers that count on us to know the regs? If someone else wants to do that, then whatever -- that's their call on how they run their business and leave their customers hanging. And, companies that act like this have historically not had a problem with this because they made their repairs quietly for the enduser. It's only when a company's actions are so loud they draw attention to the situation (and provoke responses like this) from the regulatory agency of this industry. In short: If you haven't noticed over the years, I couldn't care less if some manufacturer gets off by taking little stabs at us -- but when they feel the need to make it so obvious and un-ignorably public, they draw the attention of an agency that is tasked to regulate this industry. Last time I was up at Tech Branch, I saw there were copies of Shotgun News and other magazines open on desks, with advertisements circled - anyone that doesn't think the BATFE doesn't also look on these websites is quite foolish. It's their job to be aware of what's been going on -- and no one had to bring it to their attention. Think about it: The people that caused this are the ones making continual noise and bringing it upon us all -- not the ones keeping a low profile. You wear your shame like a crown. Kel |
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Posted: 4/17/2008 10:53:26 PM EDT
[#44]
Lately it seems more like 'we keep our heads down, do our research, and continue to copy the latest and best developments from our rivals' |
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Posted: 4/18/2008 2:53:44 AM EDT
[#45]
Kel wrote "We don't ask questions that would lead to hinder our own business".Do you ask questions that would hinder the business of anyone else?
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Posted: 4/18/2008 4:12:01 AM EDT
[#46]
Quoted:
All, The first I heard about this was yesterday from my attorney. He contacted me to inform me that BATFE was releasing the pdf I referenced, and to discuss the new data and how it affects the way the industry does business. This morning, the first official knowledge of this is when I received an email from BATFE telling me that this document was going public and a link to the pdf. ok ,,,did ATF send such a mail to ALL can manufactures,,or did they only send one to special selected ones  ,,if only to you ,,,why only you
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Posted: 4/18/2008 4:26:34 AM EDT
[#47]
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Posted: 4/18/2008 4:26:39 AM EDT
[#48]
It F4's directly back to the end user. No CLEO / No prints. |
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Posted: 4/18/2008 4:29:33 AM EDT
[#49]
STOP ATTACKING GEMTECH
No more "you suck , blah, blah, blah". Discuss the issues at hand but NO MORE ATTACKS. You don't like the ruling .... go talk to your reps, start writing letter. |
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Posted: 4/18/2008 5:07:27 AM EDT
[#50]
One word Gemtech i have several cans and they are not to far from me, NEVER will i buy from them |
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