New York 3D printer blocking technology mandate: Difference between revisions
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==Background== | ==Background== | ||
The law responds to firearms that can be produced from digital design files on consumer additive-manufacturing hardware, including untraceable ghost guns and pistol-conversion devices that turn a semi-automatic handgun into a machine gun. Governor Hochul's office presented the budget measures as a response to illegal 3D-printed ghost guns and do-it-yourself machine guns, pairing the 3D-printer rules with new criminal penalties for digital gun files.<ref name="gov" /> The gun-safety group Everytown for Gun Safety characterized the package as shutting down what it called the ''"plastic pipeline"'' of do-it-yourself firearms.<ref name="everytown" /> | The law responds to firearms that can be produced from digital design files on consumer additive-manufacturing hardware, including untraceable ghost guns and pistol-conversion devices that turn a semi-automatic handgun into a machine gun. Governor Hochul's office presented the budget measures as a response to illegal 3D-printed ghost guns and do-it-yourself machine guns, pairing the 3D-printer rules with new criminal penalties for digital gun files.<ref name="gov" /> The gun-safety group Everytown for Gun Safety characterized the package as shutting down what it called the ''"plastic pipeline"'' of do-it-yourself firearms.<ref name="everytown" /> The private creation of firearms for personal use, including via 3D printing, is not prohibited by US law,<ref>{{Cite web |date=2025-09-11 |title=Privately Made Firearms {{!}} ATF |url=https://www.atf.gov/firearms/privately-made-firearms |url-status=live |website=Bureau of Alcohol, Tobacco, Firearms, and Explosives}}</ref> but New York State has its own legislation prohibiting privately made firearms.<ref>{{Cite web |title=NY State Senate Bill 2021-S14A |url=https://www.nysenate.gov/legislation/bills/2021/S14 |url-status=live}}</ref> | ||
'''Rather than moving as a standalone firearms bill with its own floor debate, the measure was enacted inside the Public Protection and General Government article of the state budget''', as Part C of S. 9005-C / A. 10005-C.<ref name="bill" /> Part C is split into Subpart A, which adds the criminal-law definitions and file offenses, and Subpart B, which creates the working group and file library in Executive Law § 837-aa and the device-sales requirement in General Business Law § 396-eeee.<ref name="bill" /><ref name="bill-pdf" /> The National Rifle Association's Institute for Legislative Action objected to the use of the budget as the vehicle, calling it a ''"strategic move to put divisive legislation into an all-or-nothing budget bill"'' rather than passing the measure as a standalone bill subject to its own debate.<ref name="nra" /> | '''Rather than moving as a standalone firearms bill with its own floor debate, the measure was enacted inside the Public Protection and General Government article of the state budget''', as Part C of S. 9005-C / A. 10005-C.<ref name="bill" /> Part C is split into Subpart A, which adds the criminal-law definitions and file offenses, and Subpart B, which creates the working group and file library in Executive Law § 837-aa and the device-sales requirement in General Business Law § 396-eeee.<ref name="bill" /><ref name="bill-pdf" /> The National Rifle Association's Institute for Legislative Action objected to the use of the budget as the vehicle, calling it a ''"strategic move to put divisive legislation into an all-or-nothing budget bill"'' rather than passing the measure as a standalone bill subject to its own debate.<ref name="nra" /> | ||
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<blockquote>''"Three-dimensional printer" means: (a) any machine capable of rendering a three-dimensional object from a digital design file using additive manufacturing; or (b) any machine capable of making three-dimensional modifications to an object from a digital design file using subtractive manufacturing.''<ref name="bill" /></blockquote> | <blockquote>''"Three-dimensional printer" means: (a) any machine capable of rendering a three-dimensional object from a digital design file using additive manufacturing; or (b) any machine capable of making three-dimensional modifications to an object from a digital design file using subtractive manufacturing.''<ref name="bill" /></blockquote> | ||
The statute does not separately define ''"additive manufacturing,"'' ''"subtractive manufacturing,"'' or a CNC machine, and it contains no carve-out for machine size, intended purpose, or consumer use.<ref name="bill" /> Writing in | The statute does not separately define ''"additive manufacturing,"'' ''"subtractive manufacturing,"'' or a CNC machine, and it contains no carve-out for machine size, intended purpose, or consumer use.<ref name="bill" /> Writing for Adafruit, Phillip Torrone read the two prongs as reaching past consumer 3D printers, arguing the definitions ''"sweep in not just FDM and resin printers, but also CNC mills"'' along with any machine that performs subtractive manufacturing from a digital file.<ref name="adafruit-ctrlaltdel">{{Cite web |url=https://blog.adafruit.com/2026/02/03/new-york-wants-to-ctrlaltdelete-your-3d-printer/ |title=New York Wants to Ctrl+Alt+Delete Your 3D Printer |author=Phillip Torrone |publisher=Adafruit Industries |date=2026-02-03 |access-date=2026-06-02}}</ref><ref name="techdirt" /> On that reading the mandate would apply to: | ||
* '''Additive manufacturing''' (prong (a)): | |||
** consumer FDM and resin printers | |||
** machines running open-source firmware such as Marlin, Klipper, and RepRap, which Torrone noted are maintained by volunteers with no resources for compliance | |||
** printers that operate offline and never contact the internet | |||
* '''Subtractive manufacturing''' (prong (b)): | |||
** CNC mills, which Torrone wrote can machine any shape from any material | |||
Torrone added that the requirement also reaches file formats and workflows the detection algorithm cannot parse, including raw G-code, custom slicers, and parametric designs generated at print time.<ref name="adafruit-ctrlaltdel" /> | |||
Under the statute, the minimum performance standards for blocking technology are left to the working group and the rules that follow, rather than written into the law itself.<ref name="bill-pdf" /> | Under the statute, the minimum performance standards for blocking technology are left to the working group and the rules that follow, rather than written into the law itself.<ref name="bill-pdf" /> | ||
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A blocking-technology requirement is a manufacturer-side technical control fixed to hardware the buyer already owns. The Electronic Frontier Foundation has framed print blocking as anti-consumer for the same reason, treating a mandated filter on an owner's machine as a restriction on lawful use of property.<ref name="eff-permission" /> The group compared the requirement to [[Digital rights management|DRM]], calling manufacturer-provided software restrictions ''"an old tactic from the DRM playbook"'' and tracing the approach to the [[Digital Millennium Copyright Act]], which it said made bypassing DRM a federal crime.<ref name="eff-permission" /> Techdirt noted that much of the firmware running consumer printers, including open-source projects such as Marlin, Klipper, and RepRap, would not ship with a state-compliant detection algorithm, so a scanning requirement could push owners toward proprietary, locked-down machines.<ref name="techdirt" /> | A blocking-technology requirement is a manufacturer-side technical control fixed to hardware the buyer already owns. The Electronic Frontier Foundation has framed print blocking as anti-consumer for the same reason, treating a mandated filter on an owner's machine as a restriction on lawful use of property.<ref name="eff-permission" /> The group compared the requirement to [[Digital rights management|DRM]], calling manufacturer-provided software restrictions ''"an old tactic from the DRM playbook"'' and tracing the approach to the [[Digital Millennium Copyright Act]], which it said made bypassing DRM a federal crime.<ref name="eff-permission" /> Techdirt noted that much of the firmware running consumer printers, including open-source projects such as Marlin, Klipper, and RepRap, would not ship with a state-compliant detection algorithm, so a scanning requirement could push owners toward proprietary, locked-down machines.<ref name="techdirt" /> | ||
Furthermore, if someone encounters a false positive, the law does not outline any remediation or exemption procedure. The law does not even acknowledge nor even contain the term "false positive"<ref name="bill" />. Even if an algorithm is developed which has sufficiently low error rates on currently-available models, the error rate will generally increase once people start intentionally trying to find ways around it. This is known as an "Adversarial Example" and is a well-documented way to evade or deliberately confuse machine learning algorithms.<ref>{{Cite web |last=Kurakin |first=Alexey |last2=Goodfellow |first2=Ian |last3=Bengio |first3=Samy |date=2017-02-11 |title=Adversarial examples in the physical world |url=https://arxiv.org/abs/1607.02533 |url-status=live |access-date=2026-06-02 |website=arXiv}}</ref><ref>{{Cite book |last=Molnar |first=Christoph |url=https://christophm.github.io/interpretable-ml-book/adversarial.html |title=Interpretable Machine Learning: A Guide For Making Black Box Models Explainable |date=2025-03-13 |edition=3rd}}</ref> | |||
==Comparison to other states== | ==Comparison to other states== | ||
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</references> | </references> | ||
[[Category: | [[Category:American legislation]] | ||
[[Category:Right to Repair]] | [[Category:Right to Repair]] | ||
[[Category:Digital rights management]] | [[Category:Digital rights management]] | ||