One of the things that manufacturers do, is they talk to regulating agencies when they want to introduce a new product to the market. I'm sure the 3 1/2" 12 gauge shell was no exception.
I was in business 30 years ago and had to get ATF blessing before I could market a patented product I invented. The approval process was, go to D.C. with an appointment with a representative of the agency, show him the product and got verbal approval during the 10 minute meet. A letter came about 2 weeks later confirming the legality of the product. Case closed.
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