Can you build your own suppressor in Texas?

[makenzie71]

I meant like you need machining work so you hire a machinist ~ does your machinist have to be licensed or is it just you as the employer? Not as in hiring a third party to make a complete product.

 

[TX69]

 

[TX69]

Don't forget to have a smoke while shooting your suppressed gun making a video ......

 

[TX69]

 

[A.Texas.Yankee]

If all the cost of an FFL 07 is the $500/yr if sales are under $500k...that's one suppressor. Seems like limiting your sales to under $500k wouldn't be too difficult...and if you're looking to do more then the extra fees shouldn't be a problem.

I just caught this. No, it's more to it. You manufacture, you need to pay ITAR ($2250/YR), pay for license after getting approved for 07 (I think 07 is 120 every few years or so), and pay SOT ($500/yr). So about $3000 a year.

 

[A.Texas.Yankee]

I meant like you need machining work so you hire a machinist ~ does your machinist have to be licensed or is it just you as the employer? Not as in hiring a third party to make a complete product.

The machinist/company would be considered engaged in manufacturing and would have to be licensed.

No way around licencing. If your were the licensed 07 with SOT, you could employ a machinist to make them for you as the business.

 

[Acera]

The machinist/company would be considered engaged in manufacturing and would have to be licensed.

No way around licencing. If your were the licensed 07 with SOT, you could employ a machinist to make them for you as the business.

I think that is what he may bet getting at.


He can become a fully licensed manufacturer of suppressors, hire a few workers (maybe part time) to help produce his product, and sell enough to make it profitable.

In the mean time while working through the details of his design and getting set up legally and operationally, he can get some form 1s approved and begin to make his prototypes.

 

[makenzie71]

Yes that's what I meant. I wanted to make sure that not everyone involved in the operation had to be a fully functioning arms manufacturer. Bummer on the $3k a year...looking at proven designs I think I can make something effective enough and profitable enough to cover it, plus some, but there would be a pretty heavy up front investment. I'll likely abandon the "manufacturing to produce an income" idea...but may still play with it a little later.

Backing up a few steps:

If you manufacture your own suppressor, can it be made to be serviceable? That's to say if I don't like the way it works, can I gut the tube and make a new set of baffles and chambers? If it's a one time thing where you have to make it a solid, unserviceable piece then that will make getting something I want to keep pretty difficult.

After you build something, and it works, if you decide to part ways with it and build a new one, can you sell the first one you made to another individual willing to complete the necessary forms and such? I'm lead to believe this is like any other gun sale: You can't manufacture with the intent of selling, but you can sell down the line if you decide to go a different route or just want to let it go (so long as it is serialized).

 

[Acera]

makenzie71 might I suggest a couple of things that might help your decisions before ditching the idea of a small, after work business.

First, do an internet search and see what people buy and pay for suppressors, silencers, sound moderators, or whatever they are called in different nations other than the US. You can easily convert their currency into US dollars for comparison. I think you will find that the cost to purchase is significantly lower in other developed nations, that should help you figure out if you can produce and make a profit. I think the markup is high here. You might be able to cover the license costs sooner than you expect.

In the UK you can buy a 12 shotgun suppressor (they call them moderators) for £160.00 (less than $250). The cheapest one in the US has a MSRP of $1,400!!


Next look at what part of the market is undeserved and maybe think about going that way. Personally it seems like everyone is chasing decibels and weight out there. The prices keep climbing on the ones that squeeze out one more point and lose 1 extra ounce. Now look at what the best hearing protection provides. The disposable foam ear plugs I use are rated at 30, some of the best over the ear muffs are only 27, and it gets worse from there. That might be my starting point, can I replace better than normal hearing protection with my product at a reasonable price? You might not have the most technically advanced can out there, it might weigh a bit more, but it will probably be good enough and be 1/3rd the price. You might make due with less exotic materials, less intensive labor designs, and produce a product along the lines of the AK mentality, and be still a success.

Remember you will be facing the suppressor snobs on a regular basis on this forum and others. Forget about them, they may not be your intended market.

 

[Saltyag2010]

If you want to make a bunch (manufacturer), you'll need a FFL 07 and then pay 500/yr (or $1000/yr if sales exceed 500 grand) for the SOT II (special occupational tax class 2). Then you run into the realm of ITAR. Which I believe any 07 needs to file for. ITAR runs $2250/yr. Gets really expensive to make your own for profit.

So if I want to build 3 SBRs and a couple flashlight suppressors it would be best for me to pay 500/yr? Can I just pay for one year?

 

[BIGPAPIGREG]

What kind of decibel reduction do you get with something like?

not sure, a buddy of mine is looking into making one, I will ask. I plan on being there when he starts, so I can see the process...

 

[Renegade]

So if I want to build 3 SBRs and a couple flashlight suppressors it would be best for me to pay 500/yr? Can I just pay for one year?

No, if you want them for yourself it is Form 1. Licenses are not issued to folks who want to make for themselves.

 

[Younggun]

The tough thing about producing cheap cams that may be heavier or not quite and quiet is that every purchase requires an extra $200 stamp and there is no getting it back if you sell, plus the value of the can will be much lower even if it's almost new.

Most would rather spend the extra $100 to be sure they will be happy with it. Or several hundred of they want the quietest/smallest/lightest.

 

[A.Texas.Yankee]

So if I want to build 3 SBRs and a couple flashlight suppressors it would be best for me to pay 500/yr? Can I just pay for one year?

Renegade is correct, I was basing this off of it being a business for profit. Remember it's not just $500 for the SOT. You have to pay for the 07 FFL ($120 or something for all few year license), and then pay ITAR ($2250). You can pay ITAR and SOT for one year, but unless you are engaged in the business, you won't get approved for an FFL 07 to start. Now I'm sure there are people that have done just that and then dissolved the FFL, but it's illegal.

No, if you want them for yourself it is Form 1. Licenses are not issued to folks who want to make for themselves.

Correct. If not doing this with the intent to make money, get a form 1 approved to manufacture your own. Cheaper and legal!!

 

[A.Texas.Yankee]

Yes that's what I meant. I wanted to make sure that not everyone involved in the operation had to be a fully functioning arms manufacturer. Bummer on the $3k a year...looking at proven designs I think I can make something effective enough and profitable enough to cover it, plus some, but there would be a pretty heavy up front investment. I'll likely abandon the "manufacturing to produce an income" idea...but may still play with it a little later.

Yes quite a bit of upfront investment. You would be best to go in with someone as an investor or someone who is currently an FFL Dealer 01/02 looking to expand and just use their name FFL to both invest in 07. Lots of other options when you become an 07!

Backing up a few steps:
If you manufacture your own suppressor, can it be made to be serviceable? That's to say if I don't like the way it works, can I gut the tube and make a new set of baffles and chambers? If it's a one time thing where you have to make it a solid, unserviceable piece then that will make getting something I want to keep pretty difficult.

This falls into a different category. This would be research and development. If you are an 07 and have the SOT class II, you do NOT have to serialize what you are designing and are developing for research purposes, even if they function. Now, if you plan to ever sell, or other wise dispose of a functioning or potentially functional item, serialize it.

After you build something, and it works, if you decide to part ways with it and build a new one, can you sell the first one you made to another individual willing to complete the necessary forms and such? I'm lead to believe this is like any other gun sale: You can't manufacture with the intent of selling, but you can sell down the line if you decide to go a different route or just want to let it go (so long as it is serialized).

Gray area, but yes, and be super careful. More than 1 a year and the BATFE will be knocking on your door (words from my ATF representative, not mine). You can transfer it privately with the correct forms though.

 

[makenzie71]

This falls into a different category. This would be research and development. If you are an 07 and have the SOT class II, you do NOT have to serialize what you are designing and are developing for research purposes, even if they function. Now, if you plan to ever sell, or other wise dispose of a functioning or potentially functional item, serialize it.

How does "research and development" work for a private individual? I plan to make one, but I do not plan to get it perfect the first time around. I can't make the investment at all if, to do it all on the up and up, I have to start over with a new build with a new stamp with every effort.

Gray area, but yes, and be super careful. More than 1 a year and the BATFE will be knocking on your door (words from my ATF representative, not mine). You can transfer it privately with the correct forms though.

If I manufacture more than one a year (for private use) or if I try to sell off more than one a year?

 

[kfog]

Like this one?

Right now it's just a tube and end caps, I'm waiting on my form 1 to come back to make the baffles.

Should have my cerakote order in tomorrow and I'll start painting...

pretty easy to do, the waiting just suckssssss

1. Set up trust (if going that route)
2. EFile form 1 and wait
3. Procure materials (either purchase them or machine yourself) for end caps/main tube (don't do anything with baffles until your stamp comes back)
4. Engrave tube with necessary info
5. Keep waiting
6. Get tax stamp
7. Form baffles and assemble supressor
8.

 

[Acera]

The tough thing about producing cheap cams that may be heavier or not quite and quiet is that every purchase requires an extra $200 stamp and there is no getting it back if you sell, plus the value of the can will be much lower even if it's almost new.

Most would rather spend the extra $100 to be sure they will be happy with it. Or several hundred of they want the quietest/smallest/lightest.

Disagree. Not much a market for used cans. I have had buddies try and sell, they usually get raped in the process, even on what was the best they could buy at the time. We need a few makers producing inexpensive cans to get more into this area of the sport. Hopefully that will drive the price down farther.

My examples are of how that market is overpriced for the product they are producing. You can't believe the Europeans have figured out how to make cans cheap and we have not, can you?? Plus they have been more popular over there for a lot longer than it has here.

I have never had a problem with weight. While it is nice to have a quieter can, sometimes it is not necessary.

Like I said about silencer snobs, they always come out.


Kfog, you have not drilled out both end caps yet, right???

 

[A.Texas.Yankee]

How does "research and development" work for a private individual? I plan to make one, but I do not plan to get it perfect the first time around. I can't make the investment at all if, to do it all on the up and up, I have to start over with a new build with a new stamp with every effort.

R&D doesn't work for an individual. You file Form 1 and that allows you to have the necessary parts to build 1 and ONLY 1 suppressor. You can work on that one and do with it as you wish, but of you accumulate enough spare parts to create another one and BATFE shows up... Uh oh

If I manufacture more than one a year (for private use) or if I try to sell off more than one a year?

Sell. They might knock on your door if you build a bunch and make sure you still possess them all and paper work matches, but you shouldn't have to worry too much. They don't care if it's staying with you in your home. Now if they see transfer paperwork come across requesting new ownership frequently or close together, that's what sets off the red flag.

 

[makenzie71]

R&D doesn't work for an individual. You file Form 1 and that allows you to have the necessary parts to build 1 and ONLY 1 suppressor. You can work on that one and do with it as you wish, but of you accumulate enough spare parts to create another one and BATFE shows up... Uh oh

when it comes to remanufacturing I'm sure all the scrap will be just that. I just want the ability to tweak it until it works correctly. Legally. While all the things I do may not be universally legal, I never want to be one of those people who claims they didn't know that what they were doing was illegal.

Sell. They might knock on your door if you build a bunch and make sure you still possess them all and paper work matches, but you shouldn't have to worry too much. They don't care if it's staying with you in your home. Now if they see transfer paperwork come across requesting new ownership frequently or close together, that's what sets off the red flag.

Got it.