At what point does a part become a silencer part?

[LavaRed]

In the eyes of the law, at what point does a random metal part become a silencer part?

For the specific case I had in mind:
The importation of silencers or silencer parts from abroad is forbidden. Suppose a suppressor manufacturer found that certain machine operations were cheaper to perform abroad, and brought in its parts half-finished? Say, for example, that it ordered its tube stock for some suppressors already cut to size? Or the titanium stock for some K baffles already cut to length, centered and bored, and just pending the final machine operations? Same case for monocore stock?
And then, how does this become different from importing uncut tube stock, or titanium bar stock if it is expressly meant for manufacturing silencers? At what point does it become a silencer part if even the raw materials are imported with the express purpose of manufacturing suppressors to begin with?

Thanks,
Lava

[L1A1Rocker]

That would be a dangerious line to walk and be based completely at the good will of the ATF to NOT changer their mind and shut you down and arrest you.

[bikefreek]

In the eyes of the law, at what point does a random metal part become a silencer part?

For the specific case I had in mind:
The importation of silencers or silencer parts from abroad is forbidden. Suppose a suppressor manufacturer found that certain machine operations were cheaper to perform abroad, and brought in its parts half-finished? Say, for example, that it ordered its tube stock for some suppressors already cut to size? Or the titanium stock for some K baffles already cut to length, centered and bored, and just pending the final machine operations? Same case for monocore stock?
And then, how does this become different from importing uncut tube stock, or titanium bar stock if it is expressly meant for manufacturing silencers? At what point does it become a silencer part if even the raw materials are imported with the express purpose of manufacturing suppressors to begin with?

Thanks,
Lava

Knowing the .gov I would say that having the intent to make a can is prolly enough for the ATF to get bent out of shape. If you have a chunk of metal that the end result is intended to be a can i would think they wouldnt care if its finished or not.

[bikefreek]

Put it this way if they busted someone making illegal cans and in his shop he had 50 unthreaded unmarked tubes 8" long, the ATF would almost surely nail him for 50 counts

[Bargsbeer]

I was always under the impression, That even a baffle is considered a silencer. But at the same time I can go out and buy a complete MAC 10 machine gun parts kit and it be completely legit, I have also seen unfinished Glock auto sears for sale to the general public.


Just doesn't make sense. Installing a part on your gun can get you 10 years in prison.

[LavaRed]

Note that I'm talking in the case of a legally established suppressor manufacturer. Not an illegal one.

[bikefreek]

I would assume that any steps taken to the raw materials towards a finished part would be considered part of the manufacturing. And would therefore have to be performed by the company holding the license

[82nd airborne]

In the eyes of the law, at what point does a random metal part become a silencer part?

Lava

When you think about it.

[doubloon]

Put it this way if they busted someone making illegal cans and in his shop he had 50 unthreaded unmarked tubes 8" long, the ATF would almost surely nail him for 50 counts

This.

It's pretty much when the investigating agent decides it's a part.

[singtoe]

Not to be a smart ass but you will probably need to write a letter Directly to the BATFE and get you permissions. If they allow it, great, if the don't, You will have to use the high priced labor of the USA to build these suppressors.

[rockman96]

He is not in the USA.

[doubloon]

Correct, I think that's why he suggested the letter/form. Items listed in the NFA are under "restricted importation". I have no idea what "restricted" means, if it's military only, manufacturer only or what.

EDIT
But the form only seems to list destructive devices or machine guns ...

http://www.atf.gov/forms/download/atf-f-5330-3a.pdf
EDIT

[LavaRed]

He is not in the USA.

That is correct. However, an American friend of mine has recently expressed interest in starting his own legal suppressor manufacturing business in the US, after watching some of my designs. He asked me to do him the favour of doing all the research as to what he needs to do to get started, as well as give him my existing designs, come up with some other ones, and designing the manufacturing processes for him to get started. Since I have nothing better to do now that coffee harvest is over, I'm working on it. So that's why I'm asking all these weird questions abt suppressor manufacturing in the US. I ask them as they come to me, in no particular order. I'm trying to make the perfect business plan for him.

[singtoe]

He is not in the USA.

That is correct. However, an American friend of mine has recently expressed interest in starting his own legal suppressor manufacturing business in the US, after watching some of my designs. He asked me to do him the favour of doing all the research as to what he needs to do to get started, as well as give him my existing designs, come up with some other ones, and designing the manufacturing processes for him to get started. Since I have nothing better to do now that coffee harvest is over, I'm working on it. So that's why I'm asking all these weird questions abt suppressor manufacturing in the US. I ask them as they come to me, in no particular order. I'm trying to make the perfect business plan for him.

This what i figured. I assumed that he can get parts machined (especially k baffles) cheaper in Guatemala and import them to his buddies shop. I am sure you could have 20 Foreign machinist work for what 1 american machinist salary. Get your letter of approval from BATFE or buck down get an import lawyer.

[renegade]

In the eyes of the law, at what point does a random metal part become a silencer part?

Pretty much immediately:

24) The terms ``firearm silencer'' and ``firearm muffler'' mean any
device for silencing, muffling, or diminishing the report of a portable
firearm, including any combination of parts, designed or redesigned, and
intended for use in assembling or fabricating a firearm silencer or
firearm muffler, and any part intended only for use in such assembly or
fabrication.

[shotgundrums]

In the eyes of the law, at what point does a random metal part become a silencer part?

Pretty much immediately:

24) The terms ``firearm silencer'' and ``firearm muffler'' mean any
device for silencing, muffling, or diminishing the report of a portable
firearm, including any combination of parts, designed or redesigned, and
intended for use in assembling or fabricating a firearm silencer or
firearm muffler, and any part intended only for use in such assembly or
fabrication.

Hmmm
How about this. X brand .22 rifle came stock with a 16" barrel. I then install a custom barrel on it....say 26" inch.
The rifle is now distinguishably quieter. Is this still a silencer?

[renegade]

In the eyes of the law, at what point does a random metal part become a silencer part?

Pretty much immediately:

24) The terms ``firearm silencer'' and ``firearm muffler'' mean any
device for silencing, muffling, or diminishing the report of a portable
firearm, including any combination of parts, designed or redesigned, and
intended for use in assembling or fabricating a firearm silencer or
firearm muffler, and any part intended only for use in such assembly or
fabrication.

Hmmm
How about this. X brand .22 rifle came stock with a 16" barrel. I then install a custom barrel on it....say 26" inch.
The rifle is now distinguishably quieter. Is this still a silencer?

Is the barrel a device for silencing, muffling, or diminishing the report of a portable firearm?

If yes, it is a silencer, if no it is not.

[bikefreek]

Hmmm
How about this. X brand .22 rifle came stock with a 16" barrel. I then install a custom barrel on it....say 26" inch.
The rifle is now distinguishably quieter. Is this still a silencer?[/quote]

Is the barrel a device for silencing, muffling, or diminishing the report of a portable firearm?

If yes, it is a silencer, if no it is not.[/quote]

I think it would have to be intended ONLY to muffle the report...a longer barrel is also used for longer sight radius and to use all available energy in the propellant, making the muffling not its sole purpose

[singtoe]

In the eyes of the law, at what point does a random metal part become a silencer part?

Pretty much immediately:

24) The terms ``firearm silencer'' and ``firearm muffler'' mean any
device for silencing, muffling, or diminishing the report of a portable
firearm, including any combination of parts, designed or redesigned, and
intended for use in assembling or fabricating a firearm silencer or
firearm muffler, and any part intended only for use in such assembly or
fabrication.

What about orion engraving. They post on their website

Please note: Due to Minnesota state law we cannot accept threaded or registered silencer tubes. All silencer tubes must be sent prior to registration and threading. Receiver tubes must be round on both ends for this type of engraving.

http://www.orion-arms.com/gun-engraving ... aving.html

Is this a paradox?

[continuity]

What about orion engraving. They post on their website

Please note: Due to Minnesota state law we cannot accept threaded or registered silencer tubes. All silencer tubes must be sent prior to registration and threading. Receiver tubes must be round on both ends for this type of engraving.

...
Is this a paradox?

Orion's information is specific to compliance with Minnesota State law. Not relative to the ATF/NFA realm, which is a Federal oversight organization.

[LavaRed]

He is not in the USA.

That is correct. However, an American friend of mine has recently expressed interest in starting his own legal suppressor manufacturing business in the US, after watching some of my designs. He asked me to do him the favour of doing all the research as to what he needs to do to get started, as well as give him my existing designs, come up with some other ones, and designing the manufacturing processes for him to get started. Since I have nothing better to do now that coffee harvest is over, I'm working on it. So that's why I'm asking all these weird questions abt suppressor manufacturing in the US. I ask them as they come to me, in no particular order. I'm trying to make the perfect business plan for him.

This what i figured. I assumed that he can get parts machined (especially k baffles) cheaper in Guatemala and import them to his buddies shop. I am sure you could have 20 Foreign machinist work for what 1 american machinist salary. Get your letter of approval from BATFE or buck down get an import lawyer.

Yes, this was an idea I entertained, namely, having machinists here perform some of the minor operations on parts and then send them to be finished in the US. But first I'd rather ask around.
It's cost-effective in some ways. My latest .22LR suppressor cost me almost US$250 total, which is almost what a good .22LR suppressor would cost in the US. I'm sure bulk machining might be a bit more cost effective tho.
The other angle of the question is about the legality of importing the raw materials to make the suppressors. Like for example, is it legal to import titanium, stainless steel or aluminium bar stock, tube stock, etc, or does the definition of a silencer part extend all the way to raw stock so that it would have to be mined, refined and rolled in the US as well?
Thanks,
Lava

[Dan]

The ATF could easily prosecute you for importing washers if they thought they were silencer parts.

I am not sure if any company has had so much volume of parts that it made sense to import even if you could.

[Smokecloud]

What if you found a local welding shop that could benefit from purchasing raw material and the metal was sold to them to resell to whomever they want and use the material themselves. The material would be sold to someone who is not intending for it to be a suppressor, then once they have it, you could purchase the material from them, hopefully at not much of an elevated cost since you just saved them a fortune in raw material for their other projects and or customers. If not, perhaps give up on silencers for a while, start your own windchime company and purchase your materials, after 12 months when you business fails, you will have material left over after disbanding your company, to start a new company with, or is that still stretching it too thin. To be safe though, contacting ATF and splitting hairs with them would be safest