The DESCRIPTION of a PAD in its DEFINITION describes motors and reloads to perfection.
See:
27 CFR 55.11, "Propellant Actuated Device. Any tool or special mechanized device or gas generator system which is actuated by a propellant or which releases and directs work through a propellant charge."This definition is what is referred to in 27 CFR 55.141(a)(8)
55.141 exemptions (a) (8) Gasoline, fertilizers, propellant actuated devices, or propellant actuated industrial tools manufactured, imported, or distributed for their intended purposes.From this, it is commonly understood that as long as the PAD are manufactured, imported, or distributed for their intended purpose, they are exempt from treatment as explosives per 27 CFR and other laws. There is no size or volume limitation on what is exempted.
See
- Who must meet storage requirements? All persons who store explosive materials must store them in conformity with the provisions of Subpart K of the regulations, unless the person or the materials are exempt from regulation. [18 U.S.C. 842(j), 845; 27 CFR 55.29, 55.141, 55.164,
Note the reference to 55.141.
So whether or not the components are explosives, they are exempt under this special provision for propellant.
"Because it is not designed to function by explosion" no doubt.