July 24, 2020

Earlier this month, the Directorate of Defense Trade Controls (“DDTC”), an organization within the Department of State responsible for regulating the import and export of certain defense technology, published a web notice updating its suppressor policy. The notice stated that effective immediately the Department of State has rescinded its April 18, 2020 firearms suppressor policy, which “provided for enhanced guidelines for the approval and issuance of export licenses for sound suppressors and restricted their export to only official end users such as government or military entities.” The new guidance followed an interagency review which was started in 2017 that “addresses the concerns from U.S. companies [that] they were losing potential sales to foreign manufacturers of firearms sound suppressors,” a department spokesman said. According to the NRA Institute for Legislative Action, this “old policy completely excluded American suppressor manufacturers from competing in foreign markets where firearm suppressors are perfectly legal. . . and was based on the misguided idea that suppressors completely silence firearms and that similar suppressor technology isn’t already available in the rest of the world.” Pursuant to the updated suppressor policy, suppressors will now be handled by the DDTC in the same manner as any other technology enumerated on the United States Munitions List. This change in policy is expected to result in a significant increase in international sales of U.S. manufactured suppressors. The DDTC’s notice of its updated suppressor policy is available here.

For additional information on state laws and regulations applicable to the sale of firearms, please contact John F. Renzulli or Christopher Renzulli.