All, some very disturbing information, which will affect all in the shooting sports.
U.S. State Department’s Directorate of Defense Trade Controls (DDTC), which is primarily responsible for administering the Arms Export Control Act (AECA) and its implementing rules, the International Traffic in Arms Regulations (ITAR). The upshot is that DDTC is labeling gunsmiths as “manufacturers” for performing relatively simple work such as threading a barrel or fabricating a small custom part for an older firearm. Under the AECA, “manufacturers” are required to register with DDTC at significant expense or risk onerous criminal Penalties:
http://pmddtc.state.gov/compliance/Applicability%20of%20the%20ITAR%20Registration%20Requirement%20to%20Firearms%20Manufacturers%20(Publish).pdf
2. Registration Required – Manufacturing: 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:
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.
So, if you own a lathe or milling machine would that be ” Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms” What about Brownells magnabit screwdrivers?
If you convert a bolt action rifle that holds 5 rounds to be a single shot, or convert a shotgun to only hold 3 rounds, you are now a manufacturer. (See b.) They don’t state increase round capacity, only change round capacity.
If you make a stock for a custom rifle or make one for that Parker, you are now a manufacturer, make a set of double set triggers, new barrel for a custom single shot…. You are now a manufacturer (See c.)
Buying a pre threaded/ pre chambered barrel for custom installation, as soon as you touch a lathe bit to that barrel to get correct headspace you are a manufacturer (see e. & h)
And god help you if you actually thread and chamber a barrel, you are definitely a manufacturer (see e. f. g. & h)
Do you reload? “ d. The systemized production of ammunition,” all reloading by definition is systemized (to arrange in or according to a system; reduce to a system; make systematic), guess what reloaders, you are now a manufacturer. There is no distinction between personal or commercial use, and no definition on quantity. So if you produce one round in a systematic manner you are a manufacturer.
If you look at Category I (j)(1) of the United States Munitions List (USML) (22 CFR § 121.1) there is no exemption for sporting arms, or antique arms:
121.1 General. The United States Munitions
List.
1.
(j) The following interpretations explain and amplify the terms used in this category and throughout this subchapter:
(1) A firearm is a weapon not over .50 caliber (12.7 mm) which is designed to expel a
projectile by the action of an explosive or which may be readily converted to do so.
