03-22-2017, 02:21 AM
If the rubber wipes were similarly incomplete (i.e. no hole, and Dead Air wasn't also selling complete cans) there would be no issue. The ATF is basically opting to treat disposable baffles (which is what wipes are) as nondisposable baffles after two decades to the contrary. Previously, they'd recognized that the NFA process led to a ridiculous result if these wipes were considered silencer parts, to the point that the common wipe-based tech of the day was essentially forbidden (a dozen shots every 6-8 months at best), so they exercised their regulatory discretion in a way that made more sense for a product to be marketable; only the 'permanent' parts of the can were regulated.
I suspect this move was to 'head off' future polymer baffle tech that rivals metallic designs, so a 3D printed or cast-silicone monocore stack could not be claimed as a 'wipe,' or possibly even the notorious oil-filter setups (I know the filter itself is treated as the can at this time, but it could be argued in court that its durability is poor enough to be counted as a wipe, especially considering you first shoot through the thing to activate it, exactly like a solid wipe). The effect is to force those few companies employing wipes, or ablatives/meshes more generally, into the unpleasant position of selling products made unmarketable by regulation.
Thankfully the industry is not nearly so reliant on this technology as it was in the 80's, so the impact won't be quite as painful for the consumer or home builder.
TCB
I suspect this move was to 'head off' future polymer baffle tech that rivals metallic designs, so a 3D printed or cast-silicone monocore stack could not be claimed as a 'wipe,' or possibly even the notorious oil-filter setups (I know the filter itself is treated as the can at this time, but it could be argued in court that its durability is poor enough to be counted as a wipe, especially considering you first shoot through the thing to activate it, exactly like a solid wipe). The effect is to force those few companies employing wipes, or ablatives/meshes more generally, into the unpleasant position of selling products made unmarketable by regulation.
Thankfully the industry is not nearly so reliant on this technology as it was in the 80's, so the impact won't be quite as painful for the consumer or home builder.
TCB