An open letter on HB 2321 in Washington State:

[elizafox@social.treehouse.systems]

An open letter on HB 2321 in Washington State:

To whom it may concern,

I am writing in opposition to HB 2321. Beyond its technical and legal defects, the bill would have a far more severe and likely unintended consequence: it would operate as a de facto ban on additive and subtractive manufacturing equipment in Washington State, because compliance with its requirements is not realistically achievable.

1. The bill imposes impossible compliance conditions

HB 2321 requires that three-dimensional printers incorporate blocking features that:

* Reliably detect firearm-related designs; and
* "Cannot be overridden or otherwise defeated by a user with significant technical skill."

This is an impossible standard for any general-purpose manufacturing system.

HB 2321 assumes that a software algorithm can reliably determine whether a three-dimensional design file represents a firearm or firearm part, but this assumption is fundamentally incorrect. Design files describe geometry, not intent or function, and firearm components do not possess unique or invariant shapes that distinguish them from countless lawful mechanical objects. The same geometric features appear in jigs, fixtures, brackets, tools, and industrial components, and even human experts require contextual information beyond the file itself to make such determinations. Trivial transformations such as scaling, mirroring, parametric generation, or splitting a design into multiple parts defeat any database or pattern-based detection system without changing function. As a result, any algorithm permissive enough to avoid widespread false positives will be easily bypassed, while any algorithm strict enough to block suspected firearm designs will inevitably suppress lawful manufacturing. This is not a problem of implementation or maturity, but a structural impossibility: intended use cannot be reliably inferred from geometry alone.

In addition, any machine that accepts user-defined geometric input, whether a 3D printer, CNC mill, router, laser cutter, or hybrid system, can be repurposed, modified, or driven by alternative software. There is no known method in computer science or manufacturing engineering to guarantee that a technically skilled user cannot bypass or reimplement software controls.

When compliance is impossible, regulation becomes prohibition. Manufacturers faced with criminal penalties for failure to meet an unattainable standard will simply withdraw products from the state.

2. The bill’s definition of "three-dimensional printer" is extremely broad

HB 2321 defines a three-dimensional printer as any machine capable of:

* Rendering a 3D object from a digital design using additive manufacturing; or
* Making 3D modifications using subtractive manufacturing.

This definition encompasses:

* Desktop and industrial 3D printers
* CNC mills and routers
* Hybrid additive/subtractive
* Educational and research equipment
* Many forms of automated machine tools

By tying all such equipment to mandatory, non-bypassable content inspection, the bill does not merely regulate consumer 3D printers, it places an unworkable compliance burden on a vast range of manufacturing technologies.

3. Compliance would eliminate open, general-purpose manufacturing tools

To even attempt compliance, manufacturers would be forced to:

* Lock firmware and hardware;
* Restrict machines to approved software pipelines;
* Prohibit open-source toolchains;
* Submit to state-controlled algorithmic approval.

This would effectively ban open-source manufacturing platforms, research equipment, custom-built machines, and user-modifiable systems. These are foundational tools in education, prototyping, repair, accessibility device fabrication, art, and small-scale manufacturing.

Washington would become hostile to modern manufacturing not because it prohibited these tools explicitly, but because it made lawful sale impossible.

4. The bill creates a chilling effect far beyond firearms

Because the bill criminalises the sale of equipment that might be misused and requires speculative algorithmic detection of intent, manufacturers would rationally treat Washington as a high-risk jurisdiction.

The predictable outcome is:

* Manufacturers declining to sell in Washington;
* Reduced availability of manufacturing tools;
* Increased costs for compliant equipment;
* Displacement of innovation and industry to other states.

This is particularly concerning for a state that relies heavily on advanced manufacturing, research institutions, startups, and maker ecosystems.

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[77nn@goto.77nn.it]

@Elizafox

"Ciao, 'Murica!"