A lower is not, and cannot be, an SBR. A rifle is an SBR when it's configured as one (i.e., barrel < 16" and/or OAL < 26"). Put a 16+" upper on it, and it's a normal Title I rifle. Remove the upper from it and sell just the lower, and it's normal Title I firearm (and it's lost its NFA status--the buyer of the lower can't assemble it into an SBR configuration without a new approved Form 1).
To the OP: You are supposed to initially build the configuration you specify on the Form 1, but having done that you can change to whatever configuration you like, and there's no requirement to be able to return the rifle to the filed configuration. You might observe that there's then no way that ATF or any other agency could know whether you initially built it in the specified configuration--and if you don't do something like post it on the Internet, you'd be right. ATF asks, but has no basis to require, that you notify them of any "permanent" change in configuration. It's hard to call anything "permanent" with a modular platform like an AR, but if you wanted you could send them a letter after your Form 1 was approved notifying them that you're changing the configuration to a 10.5" barrel.