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About a year ago, Diversified Machine, manufacturer of Form 1 suppressor components, was raided and shut down by ATF and even their website was seized. They were one of a handful of solvent trap and Form 1 suppressor parts companies that suffered the same fate. Some, like Hawk Innovative Tech, were raided, shut down, and had all of their assets seized, yet no charges have been formally filed.

While it is 100% legal to manufacture your own suppressor, whether completely from scratch or by modifying existing components (washers, pipes, solvent traps, etc.) as I did HERE, our friends at the ATF would like you to know that you MUST file a Form 1 to register the silencer, pay your tax stamp, and receive approval on it, before you do any silencer-related manufacturing or modifying.

This letter was, as far as we can tell, just sent to every person who ever bought something from Diversified Machine . . .

In the case of my friend who tipped me off to this, he has built and registered a handful of Form 1 suppressors, machining most of the components himself from scratch. Some years ago he ordered spacers — short sections of metal tubing — from Diversified Machine to use inside of his own silencers.

This demonstrates a major flaw in this letter and in the ATF’s thinking, such as it is. While the letter asserts that the recipient bought components from Diversified Machine — and didn’t register them as silencers — the ATF has no idea if this is true or not.

When the purchaser files the Form 1, AKA the application to make a firearm, they themselves (or a trust they’ve created) are listed on the form as the manufacturer. There is no scenario in which any mention of “Diversified Machine” would appear on any Form 1 at all.

Furthermore, Diversified Machine’s primary business was selling innocuous components that could be (but don’t have to be) used or modified in the manufacturing of a Form 1 suppressor. As in my friend’s case, he did effectively register the parts he bought from Diversified when he registered the complete silencer in which those spacers were to be used.

Although the 1968 definition of “silencer” could be read to suggest that each individual sub component of a silencer is, itself, a silencer and requires registration, ATF has long-since and repeatedly made it clear that they cannot and will not interpret or enforce the law as such. Clearly.

Take a simple Form 1 scenario in which a person uses eight washers and seven spacers stacked inside a tube with a mount welded to one end and a cap welded to the other. Is this person supposed to separately register every individual washer, spacer, tube, mount, and cap? Should they then illegally obscure the serial numbers on all of the internal components when they’re welded inside of the tube? No. Clearly not.

Anyway, I suppose one takeaway here is that companies keep records and when the .gov raids them, the .gov gets those records. ATF has the names and addresses and purchase histories of everyone who ever bought from Diversified Machine. And they’re beginning to acting on it. Hide your dog.

 

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