ATF issues new FAQ for silencers

PDF file is here.
The part that bugs me is this:

If a silencer part bearing the serial number, other than the outer tube, must be replaced, the new part must be marked with the same serial number as the replacement part.
The term “repair” does not include replacement of the outer tube of the silencer. The outer tube is the largest single part of the silencer, the main structural component of the silencer, and is the part to which all other component parts are attached. The replacement of the outer tube is so significant an event that it amounts to the “making” of a new silencer. As such, the new silencer must be marked, registered and transferred in accordance with the NFA and GCA.

Argh. That’s annoying.
One would think it’d be OK to send the silencer back to the manufacturer, have them replace any damaged parts with identical replacements, re-stamp and serialed parts with replacement parts bearing the identical serial number, and then destroy the damaged components. Yes, one would be “making” a new silencer, but the net effect would be zero: you’re also destroying a silencer bearing the same serial.
Alas, this is not the case. If one needs to replace the outer tube, it counts as a new silencer, and one must go through the transfer process all over again.
Very annoying indeed.

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