I have since contacted Air Arms and Hull Cartridge by phone.
With the 97k, HW manufacture and sell the rifle in the same specification with the same fittings in Germany as they do here, and as such HC say that it is not subject to restrictions for having a silencer despite having internal baffles. The fact that it's integral to the rifle exempts it.
With the TX200 and other AA springers with shrouds, from 2000, except to certain territories, the rifles contain baffles, but like the 97K they are not removable. However as AA do not export to Germany they are unable to confirm if their rifles would be exempt or not. Some countries like do insist baffles are removed during manufacture, but it would appear that Germany may treat them the same as the 97k, however we are unable to confirm that.
Should people wish us to contact the manufacturers and gain advice in writing, where possible we will be happy to do so.
We will continue to seek clarification in the meantime from the BDS
BFTA/NSRA County Coach
CSFTA Chairman/BFTA Rep