....In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of manufacturing and, therefore, constitute manufacturing for ITAR purposes[/b]:
a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;
b) Modifications to a firearm that change round capacity;
c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);
d) The systemized production of ammunition, including the automated loading or reloading of ammunition;
e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
f) Rechambering firearms through machining, cutting, or drilling;
g) Chambering, cutting, or threading barrel blanks; and
h) Blueprinting firearms by machining the barrel.
Dave K provided this about a page ago. So far it seems that this info has not been disputed.
While it's plain to see, there is a definition of 'manufacturing for itar purposes', in the first sentence. And apparently, it's related to routine inquiries from 'persons engaged in the business of gunsmithing'.
I doubt the sky is falling, but I wouldn't be surprised if a few folks engaged in the business are made examples of. Though it isn't legislated, the various forms of executive order are thought to be enforceable as if law.
If all this hinges on the exception of 'sporting shotguns', that's sure to be an all inclusive incremental change down the road. But, we're in agreement that all other civilian firearms fall under the 'new' rules, or just the military looking ones? Doesn't seem too encouraging.
