carguychris
New member
According to the article, it's actually more complicated and insidious than that. From page 2 of the letter, boldface in original, my emphasis underlined:tobnpr said:I believe I spoke incorrectly above, when saying that all gunsmiths would now need an 07... What is clear, is that DDTC registration, and ITAR compliance is required for all of us in the business- and I don't see why one couldn't still keep an 01, and register with DDTC as a "manufacturer". IOW, do all gunsmiths now need an 07?
As I read this, the class of FFL one holds—or whether one has a FFL at all—is irrelevant. The definitions of "manufacturing" under the AECA and the GCA are "separate and distinct".ITAR registration is required of persons who engage in the business of manufacturing defense articles. Persons who do not actually manufacture ITAR-controlled firearms (including by engaging in the activities described below, which DDTC has found in specific cases to constitute manufacturing) need not register with DDTC – even if they have an FFL from ATF. As indicated above, the requirements for obtaining FFLs under the GCA are separate and distinct from the requirement under the AECA and ITAR to register with DDTC.
DDTC registration is required if one engages in "manufacturing" as defined by the Department of State. Period. Even if you're NOT a FFL.
IOW stop thinking about ATF regulations. In fact, try to forget everything you know about them. This is unrelated.