Thursday, November 23, 2023

ATF Declares Solvent Traps Have Always Been Unregistered Silencers


The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has recently shifted its stance on solvent traps, impacting many who have purchased these devices with the intention of legally converting them into suppressors. In a significant policy change, the ATF now denies the legality of solvent traps, stating they have always been considered unregistered silencers under federal law.

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For years, solvent traps have been utilized to collect cleaning fluids from firearms, attaching to gun barrels. These devices, often acquired from retailers including Chinese websites like Aliexpress and Wish, were commonly converted into suppressors by gun owners through a legal process involving ATF Form 1, a $200 tax stamp, and undergoing all necessary checks and balances. However, the ATF's recent letter to federal firearms licensees (FFLs) declares that these devices were never recognized under federal law.

“ATF has not classified any device as a ‘solvent trap,’ because that term does not exist in the relevant Federal statutes or implementing regulations,” the letter explains.

The ATF's scrutiny extends to the design features of solvent traps, asserting that many marketed as such are in fact suppressors due to characteristics aimed at reducing firearm decibels. The presence of elements such as index markings, which the ATF suggests serve as guides for drilling and converting these traps into suppressors, are a significant factor in their determination. The ATF's perspective aligns with their stance on AR-15s, where an index mark for the third hole is considered indicative of a machinegun.

Other components like baffles, spacers, and dampening material are also seen as indicators of a suppressor. "While increasing the effectiveness of a firearm silencer, these same objective design features offer no advantages in collecting or filtering cleaning solvent," the ATF states, emphasizing that even a single part like an end cap could result in severe legal consequences equivalent to possessing an unregistered machinegun.

The ATF further contends that completing paperwork to legally convert a solvent trap into a suppressor is not permissible, as the original manufacturing already resulted in an unregistered suppressor. This view effectively prohibits any legal rectification for solvent trap owners.

The importation of these items, primarily from China, adds another layer of complexity, as suppressors generally cannot be imported under the Gun Control Act (GCA) and National Firearms Act (NFA), with few exceptions applicable to civilians.

The ATF advises owners of solvent traps to consult their local field offices for guidance on divesting the devices, though it stops short of offering any immunity for those who come forward. 

Given the ATF’s hardened position and potential legal implications, Gun Coyote News urges readers to seek legal advice before contacting the ATF regarding solvent trap ownership.


  1. So are water bottles.

  2. Soon the ATF will start defining raw pipe and 2x4 as a firearm

  3. People would actually contact them ?

  4. So you can't file a Form 1 on a solvent trap, but what if you already have an approved Form 1 and a silencer built from a solvent trap?