I don't know, Dave. Maybe he should have his own propellent properly tested by a currently approved agency, and then label it according to its DOT classification. You know, like the legitimate manufacturers do?
Of course, if he doesn't want to be a legitimate manufacturer, that's fine too. He can run a black market operation if he wants. I don't have a problem with that. But that comes with certain limitations; such as keeping a low profile, not getting your motors certified, missing out on the mass market, etc. You have to stick doing business with folks who don't care if the motors they buy were legally made or legally shipped, and you shouldn't go around daring people to prove you wrong and asking to be a "test case".