The Federal Statute - "Armor-piercing ammunition is defined as any projectile or projectile core that may be used in a handgun and that is constructed ENTIRELY from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper, or depleted uranium."
ATF's decrees have not followed or is consistent with the law. They've been bullying manufacturers and sellers, and it's easier for the commercial sellers who've believed to drop the cartridges than call them on their bluffs.
It's the reason why the ATF doesn't charged anyone because it's not the law, unless it is made 100% of the hard metals listed in the law.
The word "entirely" means 100%, all, and completely made of those metals listed in the federal statute, and not 20% or 30% or 60% off - no the law says 100% as "entirely" constructed of those materials or "entirely" a combination of them.
And to add to my post that the law 8 U.S.C. § 921 deals with handgun cartridges and not rifle cartridges. The ATF wants to say the rifle round M855 is a now a handgun cartridge, which is preposterous. The M855 was and is designed as a rifle round.
You missed the “or projectile core”.
Yes I think you are right. The BATFE does not write law anyway. Congress does. They just issue regulations and this is a twisted contortion of the law. I don’t think it will stand the legal test.