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Ok boomerEngrave before assembling an NFA item.
Another option......
Colt made a limited run of M203s in 37mm. They are marked just as a original M203 would be and transfer as a normal Title 1 firearm. They are not cheap but do occasionally pop up on Gun Broker. Plus they shoot readily available 37mm rounds.
View attachment 687059
The problem with the 37mm is that you can't sub-cal them out and you cannot possess any "anti-personnel" rounds for them. All you can do is launch smoke and flares. It's my understanding that possessing like baton rounds or rubber shot on conjunction with a 37mm device puts you afoul of "constructive intent" of a DD as the launcher is no longer being used as a "signal device"
Kind of like why the flaregun cartridge inserts are illegal to use.
So the ExoticAmmo.com shotgun shell inserts that they produce cannot be used as well ?
18 U.S.C. § 921(a)(4): DESTRUCTIVE DEVICE26 U.S.C. § 5845(f)(2): DESTRUCTIVE DEVICE(Firearm having a bore of more than one-half inch in diameter)37/38 mm gas/flare guns possessed with cartridges containing wood pellets, rubber pellets or balls, or bean bags are classified as destructive devices for purposes of the Gun Control Act, 18 U.S.C. Chapter 44, and the National Firearms Act, 26 U.S.C. Chapter 53.
It is the determination of FTB that if these inserts are installed in a flare launcher or are possessed with a flare launcher they would be classified as an "Any Other Weapon," which is a firearm subject to the provisions of the National Firearms Act (NFA).