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Or is it that it's not writing one, and that RMM/emplode are simply picking up the first frame's bitrate and assuming it's the same for the whole file?

That sounds more likely.

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I'll look at cobbling together a vbrfix-like step for my app, I guess.

Is that easier than just getting Lame to write to a file instead? Your files won't play back gapless if Lame can't write its headers.

Peter