"ITAR requires that Anybody who engages in the business of manufacturing a defense article to register with DDTC and pay a registration fee that for new applicants is currently $2,250 per year, explains the NRA. These requirements apply, even if the business does not, and does not intend to, export any defense article. Moreover, under ITAR, only one occasion of manufacturing a defense article is necessary for a commercial entity to be considered engaged in the business and therefore subject to the regimes requirements.
The ATF is trying to cull many of the small time gunsmiths with this executive action-next will be the smaller dealers and there are now some larger banks getting pressure-again,to drop firearm business (look at WF and Houge)
The changes to the rules now include just about anything other than installing drop-in parts as manufacturing. This means that any service that requires cutting, fitting or special tools is considering manufacturing. If these companies wish to continue offering these services they will need to pay an additional $2,250 per year in fees.
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.
