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ATF Open Letter - Solvent Traps

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) recently examined devices commonly marketed as “solvent traps” and has determined that some of them are “firearm silencers” as defined in the Gun Control Act (GCA) and as defined in the National Firearms Act (NFA). “Solvent traps” are marketed as devices that attach to firearm barrels to catch excess solvent used when cleaning firearms. ATF has not classified any device as a “solvent trap,” because that term does not exist in the relevant Federal statutes or implementing regulations. However, ATF has classified numerous devices as “firearm silencers,” even though they are marketed as “solvent traps.”

View The Open Letter

The “solvent trap” devices that are silencers cannot be registered in the National Firearms Registration and Transfer Record (NFRTR) by an individual purchaser. Specifically, the NFA, 26 U.S.C. § 5841, mandates that the “manufacturer, importer, or maker shall register each firearm he manufactures, imports, or makes.” Therefore, it is unlawful to manufacture “firearm silencers” for transfer to individuals who have applied to make that same firearm by filing an ATF Form 1. These firearms have not been registered by the manufacturer by the close of the next business day after manufacture in compliance with federal regulation. 27 CFR 479.103. An NFA firearm that has already been made/manufactured in violation of the NFA may not be registered by the current possessor.

Current possessors of these purported “solvent traps” that are silencers are encouraged to contact ATF for further guidance on how they may divest possession. If you are uncertain whether the device you possess is a “firearm silencer” as defined by the GCA and NFA, please contact your local ATF Field Office. You may consult the Local ATF Office’s webpage for office contact information.

Please see the open letter or visit this link for additional information.

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