FICG And Dead Air Armament File An Opposition To ATF 29P

Friend, attorney and fellow blogger Adam Kraut has filed comments in opposition to ATF’s recently proposed rule-making dubbed 29P on behalf of Silencer manufacturer Dead Air Armament. If you remember from our story a few months back, 29P seeks to change the way silencer manufacturers mark their NFA-registered products. Currently manufacturers can mark serial numbers, locations and models anywhere on the silencer – tubes, end caps, etc. The ATF is proposing that going forward, only markings on tubes will be allowed.

Obviously, the rule change has broad implications for manufacturers and consumers alike. Topping the list is the possible effects on repairs to damaged suppressors and Form 1 “home-made” silencers.

From the Prince Law Blog:

The Firearms Industry Consulting Group, a division of Prince Law Offices, P.C., is pleased to announce that it was retained by Dead Air Armament (“Dead Air”) to prepare a detailed filing in opposition to ATF’s Advanced Notice of Proposed Rulemaking (“ANPR”) 29P. Dead Air has combined the brains and passion of both Mike Pappas and Gary Hughes to bring to the market some of the most innovative and anticipated silencers of the past year.

Because there is a delay in the posting of newly filed comments on, a copy is available for your viewing here.

An inspection of the docket this morning showed that no other silencer companies have filed a comment in opposition to this ANPR, making Dead Air the first in the silencer industry to take charge in the fight to prevent additional, unnecessary regulations.

Excerpts from the ‘Comments to the Opposition’ filing:

From subsection ii:

Nowhere in the docket does ATF cite to statistics, examples or other information where a silencer that was marked in a location other than the “outer tube” was unable to be identified after being recovered in a crime, was transferred between other silencer bodies that were unregistered or otherwise used in the evasion of other NFA rules. As such, the entire basis for this ANPR is at best a sham and utilized by NFATCA for its own personal agenda and positions, in the absence of any Industry support.

From subsection iii:

Nowhere in the comment submitted by NFATCA do they attempt to correct, dispel or otherwise address issues that they raised as the basis for the petition to have ATF enter into rulemaking or explain that contrary to their assertion, they do not represent the Firearms Industry. As such, they have left it to others within the community, who they do not represent, to adequately address the issues they raised. 2 Unfortunately for the rest of the community, regardless of whether NFATCA withdraws its petition, ATF is not required to have a petition to enter into rulemaking. As a result, such an action is at best more akin to a gesture to gain good will of the Industry and likely to save face, rather than to meaningfully participate in the rulemaking process that its petition was the basis for.


For the reasons set-forth above, ATF lacks the authority to define what is an “outer tube”. ATF should thoroughly consider the comments in opposition to proposed changes contained in this comment as well as the implications of the proposed changes, specifically the effects it will have on stifling innovation within one of the fastest growing segments of the firearms industry.

A copy of the filing can be found on the Prince Law Blog here.

The Firearms Industry Consulting Group:

(A Division Of Prince Law Offices)

646 Lenape Rd,
Bechtelsville, PA 19505


Dead Air Armament –

1270 Progress Center Ave, Suite 100
Lawrenceville, GA 30043

General Inquiries & Customer Support
Phone: 844-293-6778

Media Inquiries


LE – Science – OSINT.
On a mission to make all of my guns as quiet as possible.
Twitter: @gunboxready
Instagram: @tfb_pete


  • Good luck to ’em! ATF29P is nothing more than a scummy attempt by NFATCAt to drive out affordable competition using preferential backdoor federal rule changes.

    • Dave Y

      what is NFATCA’s involvement in this?

      • Budogunner

        I believe that was a play on words, combining NFA and “fat cat.” Any resemblance to another brand of alphabet soup is likely unintended.

        • HSR47

          NFATCA, or the National Firearms Act Trade and Collectors Association, is a very real orginization, and it is responsible for the mess that is both 41F, and 29P.

          Given the common accusation that NFATCA is mostly a group of MG owners interested in keeping the price of MGs high, while also trying to keep the Title II firearm market as small as regulations will permit, it’s probably entirely reasonable to call them fatcats.

      • PK

        They keep suggesting restrictive rule changes to the ATF, including this proposed marking requirement, and in the past, helping to get 41P pushed through by citing “widespread support” and similar.

  • PK

    There appears to be a quite easy way to challenge/render useless such a rule change.

    File a F1, or better yet have an 07/02 submit a F2, for one or more captured piston silent cartridges. It has no “outer tube”, and cannot be marked on the side due to brass thickness. It must be marked on the case head.

  • rdsii64

    How does only marking on the tube change anything? Can someone please explain this.
    If my can is only marked on the tube why can’t it be repaired if something happens to it.

    • HSR47

      A non-marked part can simply be replaced as a repair, and without any transfer tax liability. Additionally, rigid codifications of yesterday’s industry standards will dramatically impede future innovation.

      While a marked part can ALSO be repaired, the process cannot negatively impact the markings, and the overall dimensions of the unit cannot be radically changed (they may be slightly shortened if necessary to rethread, but cannot be lengthened).

      Given that the outer tube of a muffler, if the design even HAS one, is generally the most delicate part, and also the hardest part to effect repairs to, it makes sense that many makers and manufacturers would want to mark other parts to allow for more convenient repairs.

      FICG’s comment on behalf of Dead Air also notes several examples of mufflers currently on the market where the markings appear somewhere other than the “outer tube.” Silencerco’s Salvo 12, Osprey 9/45/Micro, and Omega 9k, Sig’s entire line of rifle mufflers, Delta P’s Brevis line, and the JJFU muffler.