John,note the "or" in the first part,AND the part in bold print "A manufacturer who does not engage in exporting must nevertheless
register.

From the ATF:
The AECA’sstatutory requirement for firearms manufacturers to register with DDTC is implemented in Part 122 of the ITAR:

§122.1
Registration requirements.
Any person who
engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is
required to register with the Directorate of Defense Trade Controls under §122.2.
For
the purpose of this subchapter, engaging in such a business requires only one occasion of
manufacturing or exporting or temporarily importing a defense article or furnishing a
defense service. A manufacturer who does not engage in exporting must nevertheless
register.

Last edited by Dave K; 08/08/16 10:08 AM.
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