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Last Friday, the ATF announced comprehensive proposed rulemaking and published a 115-page document targeting the firearms industry across the board. The rulemaking covered a range of topics, from egregious prohibitions on homemade firearm kits that are too ‘readily’ convertible to a functioning state, to new onerous marking requirements for homemade firearms that cross the books of an FFL, to a complete abrogation of the most fundamental tenants of regulatory governance with regards to firearms technology letter rulings—the ATF left no facet of the firearms industry untargeted. In conjunction with these rules, ATF is proposing a slew of new regulatory definitions, to include “partially complete . . . frame or receiver” and “readily.” Within the definition of “readily,” ATF provided a list of 8 vague factors for their use in proclaiming when such unfinished receivers are ‘too finished’ to be unregulated, effectively giving ATF unfettered authority to proclaim that a certain device or item is to be considered a regulated firearm under federal law. Amidst all of the rhetoric and discussion of those matters, further analysis of the proposed administrative rules shows that they are setting the conditions to likewise ban popular ‘solvent trap’ kits through such ‘readily’ factors-based test.

For those readers unaware of what a ‘solvent trap’ is or their regulatory history, some might say they are the ‘80%’rs’ of the silencer world. They are devices—or kits—that have a lawful use and purpose beyond silencing or muffling the sound of a firearm, but that have the potential to thereafter be used in lawful homemade silencer build projects. As their colloquial name indicates, their lawful underlying uses and purposes generally include the trapping of run-off cleaning fluids, such as barrel solvent, to prevent spillage and potential damage or staining of household upholstery, flooring, and carpeting. Additionally, some individuals may choose to thereafter file the required ATF paperwork, known as a ‘Form 1,’ to allow them to lawfully convert their lawfully owned cleaning device into a functional homemade silencer. Under present rules, this is generally allowable so long as the maker goes through the proper paperwork process, pays the required $200 tax, performs the required engraving, and does not proceed until the paperwork is approved by ATF-NFA Division.

Under the proposed set of rules published by ATF in 2021R-05, that process and understanding may all dramatically change. As with the targeting of ‘80%’ receivers and kits used to make homemade firearms, the ATF has set up the net operation of their proposed rules such that ‘solvent trap’ kits that are too ‘readily’ convertible may be likewise subject to targeting and be considered regulated silencers in and of themselves. An unfinished firearm receiver that is too ‘readily’ convertible to a functioning state will, under such proposed rules, itself be a regulated firearm, and so too, by the articulation of these rules, may a ‘solvent trap’ body or kit that is too ‘readily’ convertible be likewise considered a silencer.

TAKE ACTION NOW by submitting a comment to the proposed regulations HERE

The flowchart showing the logic used in reaching this conclusion is below. ATF Proposed Rule 2021R-05 is likewise attached for reference.

Click here to download the ATF Proposed Rule 2021R-05 document.

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