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Thus, wetted nitrocellulose containing greater than 12.6 percent nitrogen may be lawfully shipped, transported, or received
nitrocellulose wetted with water not less than 25 percent by mass is not subject to regulation under the federal explosives laws.
Sounds like simple math to me. Keep the nitrogen percentage at 12.5% max. and the H2o at 25% min. and you are within the EO.
Dry the nitrocellulose to correct level and add nitrogen to the correct level.
Not a scientist, but I'm sure the folks at IMR, Hodgdon, Accurate Arms, Winchester and others are...
That's what the were doing before this new ruling. It seems now that wetting no longer provides for an exemption:
"However, because nitrocellulose retains its explosive characteristics when the water or alcohol is removed, the wetted nitrocellulose remains a nitrocellulose explosive subject to all controls of the federal explosives laws."
In other words they've closed the "wetting loophole" which will make transporting and storing the raw materials needed to produce smokeless powder much more expensive.
"Industry members have relied on the exemption for wetted nitrocellulose for many years and are aware of no accidental detonations or diversion of this product into illicit channels. Consequently, it is unclear why ATF believed it necessary to change its policy and, more importantly, why ATF announced the change in a newsletter article with no advance notice to industry."
It's very clear actually.