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Must be that, unlike my state, the BATFE does not consider an air rifle to be a firearm?
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A silencer is a regulated device regardless of what it is attached to--even if it is attached to nothing at all.
If the device can be attached to a firearm and would reasonably be expected to reduced the sound of the discharge of the firearm--even for only one shot--then it fits the definition of a silencer and is subject to NFA regulations.
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I have a suppressed .22 cal air rifle from the factory and I can't hear much difference in one that doesn't.
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There are a variety of different airguns with different powerplants. Spring-piston or gas-piston airguns usually don't exhibit much reduction in discharge noise when a silencer is attached while PCP airguns can be almost totally silenced by the addition of a quality suppressor.