If you own or are considering purchasing a suppressor in Michigan, you have probably seen the headlines about the recent federal court ruling involving the National Firearms Act.
UPDATE — October 9, 2026: ATF Announces Nationwide NFA Enforcement Policy
Since this article was originally published, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has announced a nationwide federal enforcement policy affecting certain National Firearms Act (NFA) requirements for suppressors, short-barreled rifles (SBRs), short-barreled shotguns (SBSs), and certain other weapons (AOWs).
Under this policy, ATF will no longer enforce specified federal NFA approval, registration, and related requirements for covered items. This is an enforcement policy, not a repeal of the NFA, and it does not override state law.
Michigan law presents a separate issue. Michigan’s silencer statute contains an exception tied to federal licensing, and Michigan Attorney General Opinion No. 7260 interpreted that exception in relation to federal approval requirements. ATF has cautioned that it cannot determine whether possession under its federal enforcement policy satisfies a state’s legal requirements.
Red Circle Tactical will continue following its established NFA transfer process for Michigan transactions. Customers should not assume that ATF’s federal announcement automatically eliminates Michigan’s requirements.
For current federal guidance, consult the ATF NFA Transfer Guidance and FAQs and the ATF Open Letter dated October 9, 2026.

The seven-day stay on the court’s injunction has expired, and the first suppressor transfers covered by the injunction have reportedly taken place without Form 4 approval or federal NFA registration.
That naturally raises an important question for Michigan gun owners:
Can Michigan residents now purchase a suppressor without going through the traditional NFA approval process?
Not necessarily. While the recent federal court ruling has significantly changed the federal NFA landscape, Michigan has its own statute governing suppressors, and the interaction between the federal ruling and Michigan law is not yet fully settled.
The Federal Policy Has Changed
The August 2026 court ruling initially applied to the parties and transactions covered by the court’s injunction. On October 9, 2026, ATF announced a nationwide enforcement policy extending specified non-enforcement provisions to covered items beyond those protected by the original injunction.
The federal policy has therefore changed since this article was first published. However, the announcement does not repeal the NFA or invalidate independent state firearms laws.
For Michigan suppressor owners, the important distinction is that a change in federal enforcement policy does not automatically resolve the requirements imposed by Michigan law.
Michigan Law Still Matters
Michigan law specifically addresses mufflers and silencers under MCL 750.224.
The statute generally prohibits the manufacture, sale, offering for sale or possession of a muffler or silencer, subject to specific exceptions contained in Michigan law.
One of those exceptions applies to a person licensed by the federal government to manufacture, sell or possess the device.
That creates an important question following the federal court ruling:
If federal law no longer requires ATF registration or approval for a particular suppressor transaction, does that transaction still satisfy Michigan’s separate statutory exception?
That is an important question for Michigan dealers and gun owners.
The federal ruling did not strike down Michigan’s statute.
The Federal Injunction Does Not Automatically Change Michigan Law
Michigan law specifically addresses mufflers and silencers under MCL 750.224. The statute generally prohibits manufacturing, selling, offering for sale, or possessing a silencer, subject to statutory exceptions.
Michigan Attorney General Opinion No. 7260 concluded that possession, manufacture, or sale of a silencer is permitted under the applicable exception when the person is licensed or approved by ATF as required by the statute. See the official Michigan Attorney General opinion.
ATF’s October 9 policy changes its enforcement of certain federal NFA provisions. It does not amend MCL 750.224 or determine how Michigan’s statutory exception applies under the new federal policy.
For Red Circle Tactical, the practical result is unchanged: we will continue following the established NFA transfer process for Michigan suppressor transactions. We will not treat ATF’s announcement alone as authorization to bypass that process.
Who Is Actually Protected by the Federal Injunction?
The August 2026 court injunction applied to the plaintiffs and other parties specified in the court’s judgment. Its original scope was limited.
On October 9, 2026, ATF announced a separate nationwide enforcement policy for specified NFA requirements affecting covered SBRs, SBSs, suppressors, and AOWs. The scope of that federal policy is no longer defined solely by membership in an organization or coverage under the original injunction.
However, ATF’s nationwide policy does not resolve whether a particular transaction complies with state law. Michigan requirements must be considered separately.
What About Form 4s?
Under ATF’s October 9, 2026, nationwide enforcement policy, the agency will no longer enforce specified NFA Form 4 approval and registration requirements for covered suppressor transfers at the federal level.
That does not automatically settle the requirements for a Michigan transaction. Michigan law separately regulates silencer possession, and the state’s statutory exception has previously been interpreted in relation to federal licensing and approval.
Red Circle Tactical will continue using the established NFA transfer process for Michigan suppressor transactions. Customers should contact us before ordering or arranging a transfer rather than assume that the federal policy permits a no-Form-4 transaction in Michigan.
Applicable Gun Control Act requirements—including Form 4473, background checks where required, and dealer recordkeeping—remain in effect. ATF continues to accept voluntary NFA applications.
For the current federal position, see the ATF NFA Transfer Guidance and FAQs.
Why Red Circle Tactical Is Continuing the Existing Process
ATF’s October 9 announcement changes the federal enforcement policy, but it does not resolve every issue affecting Michigan suppressor transactions.
The considerations relevant to our established process include:
- How Michigan’s silencer statute applies under the new federal enforcement policy.
- The relationship between the state’s statutory exception and federal licensing or approval.
- Applicable federal and state requirements for the transaction.
- Required dealer records and documentation.
- How the transaction should be handled if the suppressor is later transported, repaired, or transferred.
- The need for a defensible compliance process for both the customer and the dealer.
These are not questions we believe should be resolved at the counter based solely on headlines, online discussions, or another dealer’s practices.These are not questions we believe should be answered at the gun counter by a customer, a social-media post or an internet article.
What Is Red Circle Tactical Doing?
For now, Red Circle Tactical is continuing to follow the established NFA process for suppressor transfers in Michigan.
We are closely monitoring the federal litigation, NSSF guidance, ATF developments and any additional information concerning Michigan law.
We recognize that the federal ruling could ultimately result in a significant change in how suppressors are transferred.
But until we can verify that a particular transaction satisfies both federal and Michigan law, we will continue using the established process.
That isn’t ignoring the court ruling.
It is making sure we understand exactly what the ruling means before putting a customer or our FFL at risk.
What Should Michigan Customers Do?
If you are considering purchasing a suppressor in Michigan, do not assume that ATF’s October 9 federal announcement automatically allows you to take possession without following the established NFA process.
Red Circle Tactical continues to follow that process for Michigan suppressor transfers. Contact us before ordering if you have questions about a particular suppressor or transaction.
ATF’s nationwide policy and Michigan’s separate statutory requirements must not be confused. The federal announcement does not itself amend Michigan law or determine how Michigan’s statutory exception applies.
What Happens Next?
ATF has now published its nationwide enforcement policy and related guidance. Future federal or state developments could still affect how suppressor transactions are handled.
Red Circle Tactical will continue monitoring official ATF guidance, Michigan law, and relevant legal developments. We will change our established Michigan transfer procedures only when we have a verified basis to do so.
For current federal guidance, consult the ATF NFA Transfer Guidance and FAQs.
The Bottom Line for Michigan Gun Owners
TF’s October 9, 2026, announcement significantly changes federal enforcement of certain NFA requirements. It does not repeal the NFA, override state law, or automatically resolve Michigan’s separate requirements for suppressors.
Red Circle Tactical will continue following the established NFA transfer process for Michigan suppressor transactions. Contact us before purchasing if you have questions about the process.
This article is provided for general informational purposes and is not legal advice. Federal and state firearms laws can change, and individual circumstances may affect the legality of a particular transaction. Consult qualified legal counsel about specific circumstances.
This article is provided for general informational purposes and is not legal advice. Federal and state firearms laws are subject to change, and individual circumstances can affect the legality of a particular firearm or transaction. Customers with questions about their specific circumstances should consult qualified legal counsel.





