We do have some additional information today.
Their position is basically that all solvent trap parts & kits have been determined to be silencers/silencer parts. This is not a surprise, they've been going after solvent trap companies for some time, and many of us knew that day was probably coming, especially as the traps and internal parts for them became more and more advanced and the advertising more and more prevalent in Form 1 suppressor groups & boards. When you start making "sauce cups" out of Inconel and Stellite and pushing them in groups predicated on building silencers, it becomes pretty difficult to argue they're meant for condiments and not superheated gasses.
They are claiming that people who were not planning to use any "existing silencer parts", which we still don't and likely never will have a clear definition on where they draw that line, will need to provide details on the materials, sources, design, machining methods to get approval. It is unclear if those Form 1s will be resurrected or require a new filing.
We don't know what the ATF's plan is for all the companies who had been making traps, filters, etc. It would have made more sense to send out C&D orders to them before pulling this nonsense, but at this point, the extreme majority have voluntarily shut down operations and poofed websites. I personally can't imagine they'd try to go after any of the ones who ceased production before even getting an order to, would definitely be a case of ex post facto.
We also don't know if they have plans to determine existing approved Form 1s built on/with trap parts or kits are contraband. Again, that is a pretty sticky situation with ex post facto, since these things have been around for quite some time, publicly advertised and sold, and it's common knowledge in the industry that they were being converted into silencers.
So, yeah.........we don't know a ton, but we know that they are now considering all solvent trap parts and kits bought with the intent to make a silencer to have been silencer parts and therefor illegal to possess.
If you have such things around that were not yet converted, don't file a Form 1 for them now. It'll be denied, or you'll have perjured yourself stating that you weren't using such parts in the build you applied for. Whether you dispose of them or decide to use them as actual traps or for some other purpose is your choice to make, but do so with the understanding that if the .gov decided to go after you on it and had any way of demonstrating your intent was to build a silencer, including social media conversations or text messages about them, you might be sitting on a felony.
