You may be correct. However I won't say any of it is even remotely "clear". Especially since I have sent multiple emails to a new dedicated form1 silencer specific ATF email address. With the responses to be completely lacking in anything even close to an answer to my questions or an explanation on how to not be denied upon another attempt at filing form 1s again.GSO wrote: ↑Sat Apr 16, 2022 2:30 pmIt seems a bit more clear (at least to me) now that ATF final rule 2021R-05F, Definition of “Frame or Receiver” and Identification of Firearms has been published on 11 April 2022. Reading through it (no small task....okay, maybe skimming instead of reading), it appears that the intent is for the parts (in the case of suppressors, the tube) that can be "readily made into a firearm" are treated as a firearm and serialized. For 80% receivers, this would be the receiver itself. For suppressors, the tube that holds the baffles is considered the critical part as described in the new rule. As pointed out, there are lots of tubes that "could" be made into a silencer, but not without baffles. If a tube were specifically sized to take a certain set of baffles (perhaps as a kit), then the tube would be a "silencer" when purchased. In this case, I would think it could then be Form 4'ed instead of Form 1'ed. It seems like an attempt to make things more "clear" when differentiating between manufacturing and purchasing, but oftentimes regulations or legislation has the opposite affect of the intent. Speaking of intent, I think that is important for the ATF in deciding if a piece of pipe or metal tube 'is' or 'is not' a silencer. If a baffle stack is in proximity (or if you have an oil filter with a hole in it and a solvent trap threaded insert), then it is reasonable to assume intent. In either case, it appears that the thinking is that one is not making (or manufacturing" a firearm/silencer, you are purchasing it and the Form 4 would be the correct/legal way to do it. However, this would force the seller to become an SOT which would certainly impact availability.
Please note: I am not saying that I agree or disagree with any of this. It is my attempt to explain what I see as the handwriting on the wall. I could be wildly wrong in my speculation.
I will find out eventually, since I tried again and answered the new questions now asked while filing the form 1.
The whole process and interpretation the ATF has decided on is ignorant and stupid. Shows a complete lack of anything even remotely close to common sense.