I have a question for you SOTs out there

[okie]

I have a silencer design I'm wanting to bring to market, but it's 3d and requires a very special and very expensive machine to make. I found an aerospace shop out of state that has the machine, but they don't have their SOT. The engineer that works for them who runs the machine is 2A friendly and very gung ho about the idea. The owner is willing in principle to get licensed, but doesn't want to invest the time until he sees that it's worth it.

Are there any loopholes that would allow them to manufacture under my license? Like let's say I get a license and "hire" the engineer who would be making them. Could he manufacture them there?

[utahjeepr]

Not an expert, but I am fairly certain that whomever actually manufactures the silencer has to have a class 7 and the SOT. The only exception I am aware of is an individual manufacturing their own with an approved Form 1.

[SteyrAUG]

Not an expert, but I am fairly certain that whomever actually manufactures the silencer has to have a class 7 and the SOT. The only exception I am aware of is an individual manufacturing their own with an approved Form 1.

Mostly this. Gonna need to comply with ITAR and probably send a test model to ATF for approval. If the product would be considered yours, you too would have to be an 07/SOT. You can have outside vendors do some work, just as manufacturers can have other people do their engravings. But certain parts that are specifically considered NFA must be done by the 07 himself.

Not sure which parts ATF considers "controlled" these days but they used to freak out over wipes which are rubber donuts similar to washers.

[okie]

Not an expert, but I am fairly certain that whomever actually manufactures the silencer has to have a class 7 and the SOT. The only exception I am aware of is an individual manufacturing their own with an approved Form 1.

So like if an SOT sent his finished silencer to be heat treated, the heat treating facility would also have to be an SOT?

That's kind of a bad example, though. In our case, the silencers that come out of the printer wouldn't be finished. They would get finished by the machinist, who is in fact the SOT in question. To actually function, you have to take the raw part out of the machine and ream the bore and thread it. It's kind of like an 80% receiver in the state that it comes out of the printer. It's more than a forging but by no means a finished functional product.

[utahjeepr]

So in your example "I" would not construe it to be a silencer until it at least has a bore and can be attached to a firearm in some way, shape, or form.

How the BATFE might construe the same item is anyone's guess. Stated intent weighs a lot though. If you say they are silencer baffles then they are silencer baffles and I'd damn sure want to have my ducks in a row before I'd risk making them for you. Livelihood and freedom is a lot to risk.