The petition sent by the NFATCA to ATF Director Sullivan in 2008 represented the direction and guidance of the firearm suppressor community in 2008. The request was, in fact, driven by multiple requests by the manufacturers. 2008 was a different time, with different products in the marketplace, different manufacturing techniques and different best practices. ATF's waiting 8 years to address those concerns is neither helpful nor responsive. The current market, products, techniques and best practices bears little resemblance to the past. The concerns expressed in 2008 are not applicable to today.
As such, the NFATCA formally withdraws its petition and urges ATF to recognize that exclusive tube marking does not address the varied innovations of legal firearms in the marketplace. Marking placement should encourage accurate identification for tracing and documentation purposes, should maximize consumer value, and should not hinder industry in bringing modern designs, materials, and manufacturing techniques to bear. In light of the fact that any part of a suppressor is deemed to be a suppressor, this can be accomplished by allowing marking to be placed wherever and however the manufacturer chooses, as long as the minimum height and depth requirements are met.
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