Yeah, but you'll also notice that Jerry didn't have ATF doing a Gestapo on him at 4 a.m. and throwing his butt in the slammer. Presumably they merely told him that he didn't have the necessary permits to manufacture and sell motors, and told him to stop.
Compare that to the reloads-for-PADs issue. So far ATF hasn't told anyone that reloads for exempt PADs are not exempt. Until they do, we should treat them as exempt instead of handwringing and fretting.
When and if the ATF says reloads for PADs are not exempt, then we can work the problem instead of handwringing about "what if".