Well…that's a problem.
I own a lathe as well as quite a bit of 6061-T6 bar stock I'd planned to use to build a couple suppressors. It sounds like they are denying any and all Form 1s - which means they are not even reviewing them.
To be honest, I can see why the ATF may have decided to do this since everyone and their dog was buying suppressor kits and then drilling a few holes to complete them. Like 80% receivers it was not the congressional intent that it be that easy to "make" a "firearm". By definition the tools and skills required were intended to make it a self limiting process, rather than an easy way for everyone to have one.
On the other hand ATF managed to approve Form 1s in about a month compared to 9-13 months for Form 4s so they seem to have been using the delay to intentionally limit interest in buying a suppressor from a manufacturer.
The fact that manufacturers also charge way more than they cost to produce is another disincentive that pushed people toward Form 1s and created a market for suppressor kits.
I also strongly suspect suppressor manufacturers are pleased with this ruling if they were not outright lobbying for it as it protects their market - and their price gouging.
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However this ruling is also going to create problems for the ATF. A small problem is that they blanket denied 850 Form 1s and will have to refund $170,000 in fees.
Another not so small problem is that the blanket denial will also create pushback and control letters that have to be addressed in a timely manner for each case where a denied applicant complains to a senator or congressman - requiring the ATF to explain its action in each individual case.
(If you've been denied, contact your senator and request they contact the ATF for an explanation in your particular case. Also ask how the ATF was legally able to make a major reinterpretation of a federal regulation without going through the *required* public notice and comment periods.)
The large problem is that the people who bought suppressor kits, solvent traps, fuel filters, etc, thinking they might someday send in a Form 1 and use the parts to make a suppressor have now essentially been told they already own suppressor parts, which are illegal. Some folks will dispose of them. But many others will just say "f…ine" and complete it as an unregistered suppressor. When you deny people a legal path to something, many of them will do it anyway. Immigration is a great example. Eliminate or severely limit work permits and you'll just end up with lots of people working illegally and you just lose the income tax you'd have otherwise gotten.
