With the NFA tax stamp now at $0 and suppressor demand surging, more gun store customers are asking about suppressors than ever before. Dealers who handle suppressor inventory face a specific set of compliance obligations layered on top of standard FFL requirements.
The Form 4 Process Overview
A retail suppressor sale to a non-dealer individual requires ATF Form 4 (Application for Tax Paid Transfer and Registration of Firearm). The Form 4 is filed by the dealer (as the transferor) on behalf of the buyer (as the transferee). The application must be approved by the ATF before the suppressor can be transferred to the buyer.
This means the suppressor sits in your inventory — logged in your bound book — until ATF approval comes back. The buyer cannot take possession until the approved Form 4 is in hand.
The Form 4473 on Suppressor Sales
A Form 4473 is required for every suppressor transfer, just as for any other firearm. On the Form 4473, Question 24 should have both the appropriate firearm type category and the "other firearm" box checked for NFA items. The suppressor should be described accurately in Section A.
Common error: Completing the Form 4473 but failing to check "other firearm" in Question 24 for the NFA designation. Suppressors are Title II firearms — they require the additional checkbox.
Bound Book Requirements
Suppressors must be logged in your acquisition records when they come into your inventory. They must be logged as disposed when the Form 4 is approved and the transfer occurs. If a Form 4 is denied or the customer backs out, the suppressor remains in your inventory until it is otherwise disposed of legitimately.
Processing Times and Customer Management
With the tax stamp at $0, ATF processing times for Form 4 applications have been under pressure. Current timelines vary. Set clear expectations with customers at the time of sale that possession cannot occur until ATF approval — and that timelines are outside your control.
Dealer-to-Dealer Transfers
Transfers between licensed dealers (SOT to SOT, or dealer to distributor) use Form 3, which is tax-exempt. Form 4 is for transfers from a licensed dealer to a non-licensed individual. Make sure your staff understands which form applies to which type of suppressor transaction.
Know Every Form Is Clean Before Your Next ATF Audit
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