WASHINGTON — While individual Americans are wondering why they have to register a welded tube that provides hearing protection with their government, the Trump administration is moving forward with new rules that will make it easier for suppressor manufacturers to export to markets abroad. In a closer reading of the rules, there might be a hidden message for gun owners and lawyers alike.
On July 22, the NSSF (the firearms trade industry association) announced the posting of interim final rules (effective November 20) by both the Commerce and State departments that will ease the ability of suppressor manufacturers to access foreign markets by removing administrative and regulatory burdens. (Both rules have a 30-day comment period.)
“The Final Rules are a tremendous boost to ensure American suppressor manufacturers can compete on an even playing field in overseas markets without burdensome and unnecessary regulatory burdens imposed on exporting USML items that made commercial export of suppressors economically impractical,” said Lawrence G. Keane, NSSF senior vice president and general counsel, in a press statement, adding, “These reforms will make American suppressor manufacturing an international competitor for what is essentially a muffler for a gun. In most of the world, recreational marksmen and women and hunters typically use suppressors that they can buy at a local hardware store or sporting goods retailer.”
In order to accomplish this, the State and Commerce departments have issued coordinated rules that remove semi-automatic and non-automatic suppressors from the USML (United States Munitions List) and place them on the CCL (Commerce Control List). Or in simpler terms, they have recategorized some suppressors from the government’s list of military weapons and sensitive gear to its list of “dual-use” items that can have both civilian and commercial uses, many of which are already widely used by civilians.
(The NSSF notes that they have lobbied for this effort for over a decade, and that the recent momentum began with President Trump’s April 2025 executive order on foreign defense sales.)
In making this transition, the government made some eye-catching statements about suppressors, including the admission that, “As part of this review, the Department has determined that silencers, mufflers, and sound suppressors… no longer provide a critical military or intelligence advantage.”
While the manufacturing industry in the United States naturally sees this as a win, individual gun owners are left with the impression that big business trumps individual liberty. The same federal government loosening international trade restrictions for manufacturers continues to defend the mandate for individual suppressor registration under the National Firearms Act in court as recently as earlier this month.
Put another way, the federal government is mobilizing significant resources within some of its largest departments in order to reclassify suppressors so that American manufacturers can reach larger markets, while continuing to impose limitations on individual Americans who wish to use the same firearms accessory for hearing protection and eco-friendly hunting.
However, there may be more than meets the eye in the recently proposed final rules. The Department of State rule in particular offers an enigmatic observation in its assessment of why suppressors are no longer a topic du jour:
- growing global adoption of firearm suppressors for civil uses
- the reported benefits associated with reduced firearms noise
- the existence of numerous foreign manufacturers of such items
- and the Department’s assessment that barriers to acquiring the instructions, materials, and skills to effectively manufacture these items have become appreciably lower
Each of those bullets speaks to a significant topic of discussion in a changing cultural and legal environment surrounding suppressors.
The signing of the July 2025 “One Big Beautiful Bill” ended the $200 excise tax on NFA items, suppressors included. Subsequent to its passage, gun rights groups filed at least three – if not four – significant lawsuits against the National Firearms Act itself and its remaining registration requirements.
While some elements of the Department of Justice have been defending the NFA in court, as previously mentioned, we now see the Civil Rights Division defending the possession of suppressors in a lawsuit it initiated against Washington, D.C.’s ban. In that suit, the brief points out that suppressors are in common use by Americans with more than six million in circulation.
In that context, the State Department’s admissions that suppressors are growing in adoption, provide obvious hearing protection benefits, and can effectively be made at home, could be a forerunner to the federal government softening its position on private ownership of suppressors by civilians. Might they withdraw their defense of the NFA in court?
A savvy lawyer might include these observations in an amicus brief and oral arguments in defense of ending the NFA. After all, if the federal government is willing to allow American manufacturers to sell suppressors to other countries where they are not nearly as regulated at the individual level, why should they be so heavily regulated here?
The government’s coordinated efforts to reclassify suppressors in order to help manufacturers COULD be a hint at its future posture towards how it views suppressors in civilian hands, but only time will tell.
