I interpret the definition of "Significant Military Equiptment" and "defense articles" to be firearms that are to be used by our military. Not civilians. I do not see how it can be interpreted any other way. But that is just me...
Even if this was the absolute intent and limitation of the ITAR regulations, it would still include millions of military surplus and military styled firearms such as 1911's, M1 Carbines, Garands, 1903 Springfields, etc. Since it doesn't specify U.S. Military equipment, it could easily include Mausers, AK's, SKS's, and many more. But if we choose to ignore canvasback's warning about the intent being twisted and expanded, it is only because we also choose to ignore past history of the anti-gunners.
Why on earth would our government sign on to regulations that would restrict and tax gunsmithing work on firearms used by our own military? That's about as likely as making the U.S. Marines undergo background checks. I think the ACGG is more than justified in their concern that this is aimed at civilians. Those who think otherwise would be advised to do some research into what happened to the noted custom flintlock gunsmith John Bivens when the BATF decided that this builder of fine flintlocks was subject to manufacturers excise taxes and penalties.