Once again, I point out that those two lines you cite are no applicable to M855. In particular, the first one. There is no alloy of the metals you list which “construct entirely” the round. The majority of the rounds mass is lead.
The projectile core is not constructed entirely of steel. Steel is ~15% of mass, and it’s not alloyed or compositionally part of the whole core.
The projectiles jacket is not 25%+ of the mass.
While they may get their way rule wise from bureaucratic inertia, their argument would never stand a legal interpretation of the rule (with competent and uncorrupted judiciary of course).
Heck, you could probably make a real AP round that would pass this definition as non-AP and exceed M855 penetration specs by having a 76% hard lead alloy or bismuth core and 24% jacket of something like titanium or tungsten or chro-moly steel...
I understand what you’re saying and I’m not arguing whether M855 would or would not meet the true definition of AP. I agree that it does not and we both know that it is not AP any more than any other high velocity rifle round. I’m only pointing out that the BATFE disagrees with us and is specifically targeting that ammo in their memo based on their interpretation of AP.
We can argue that M855 is not AP, but the BATFE is attempting to lump M855 ammo into the AP category. Maybe they’re interpreting the combo of alloys, the projectile versus projectile core, or the way they weigh the mass differently than you or I would. I really don’t know, but I do not trust this admin and I don’t know if it would be easily reviewable by the courts.
What I do know is if they succeed in their efforts to restrict M855 under this rule change, then they could easily come after most rifles rounds since they can now be found in handgun platforms too.
Since the exemption is based solely on the discretion of the US AG, the decision to remove the exemption may not be reviewable by the courts either.
Try pewter for that core. Easy to work with, and easily castable with a home workshop setup into a steel-jacket bullet with the [presumably] lead melted out of it.