This company was probably on ATF's radar for some other dumbassery. IIRC, one of the guys at Q has commented on suppressor tube replacements, saying that you could take a registered "can" and transfer its serial number to a new tube with entirely different internal baffles (destroying the old tube) and that would be legal.
Seems like the sort of thing that would earn a company some extra scrutiny.
This. All that's necessary is for a company to get onto the radar of the ATF. They'll keep scratching until they draw blood.
Here's the manufacturer's recommendation:
[Begin quote] Q encourages possessors of the Honey Badger Pistol to take these proactive measures until a resolution is reached between Q and ATF.
1. Complete one of the following:
A: Remove the barreled upper receiver from the lower receiver and dedicate it as a replacement for another AR-style pistol or registered short-barreled rifle; or
B: If you do not possess another AR-style pistol or registered short-barreled rifle, remove the barreled upper receiver from the lower receiver and temporarily transfer it out of your possession by, for example, transferring it to the dominion and control of another individual; and
2. Once the previous step is completed, you may file an ATF Form 1 to register the lower receiver as a short-barreled rifle. Upon Form 1 approval, the firearm may be reassembled.[End quote]