Sure by the letter of the law you are right but this is NOT reality on the ground.
Open a laser engraving company that does guns (even with owners in attendance) without an FFL and see how long it takes you before the ATF magically appears and tells you that you need an FFL to do it to guns. I would give it less than a year. They give zero f***s whether you retain customer guns or not.
It's not the law but it is for all intents and purposes "necessary".
Many years ago there was a laser engraving outfit in MA that would do guns while you waited. No FFL. They never kept the guns. They only worked on the guns while
the customer was there nearby the machine, even. None of that mattered. Feds came in and told them if they didn't stop they were going to get whacked unless they got
an FFL. They ran away like a scalded dog and immediately announced they would no longer do any gun work of any kind.
Someone could probably get an attorney and "Fix" this problem but for a business owner this is a waste of money. It's cheaper to just get an FFL and make them go away.
ETA: There is a wallhack for this sort of thing though. An engraving operator could easily conduct business under someone else's FFL if they're coloed or
whatever.