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manufacturing of defense articles means something different in reference to DDTC/ITAR than it does ATF
Registration not Required – Not Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is not required because the following activities do not meet the ordinary, contemporary, common meaning of “manufacturing” that DDTC employs in implementing the ITAR and, therefore, do not constitute “manufacturing” for ITAR purposes:
a) Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;
b) Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation;
c) Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;
d) Hydrographic paint or Cerakote application or bluing treatments for a firearm;
e) Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a pre- threaded muzzle;
f) Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;
g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and
h) Manual loading or reloading of ammunition of .50 caliber or smaller.
Activities limited to the domestic sale or resale of firearms, the occasional assembly of firearms without drilling, cutting, or machining, and/or specific gunsmithing activities that do not improve the accuracy, caliber, or operations of the firearm beyond its original capabilities (as described above) are not manufacturing within the context of the ITAR. If you are not manufacturing, exporting, temporarily importing or brokering defense articles or services, you are not required to register with DDTC.
If you are not drilling/milling/cutting etc you may be a BFF to the ATF but not DDTC. I will get clarification.
A good example thoigh, handloading under .50 cal is not mfg according to DDTC but if you are in the business of making ammo the ATF says you are a manufacturer. DDTC says it has to be systymated to be a mfg.
Registration not Required – Not Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is not required because the following activities do not meet the ordinary, contemporary, common meaning of “manufacturing” that DDTC employs in implementing the ITAR and, therefore, do not constitute “manufacturing” for ITAR purposes:
a) Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;
b) Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation;
c) Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;
d) Hydrographic paint or Cerakote application or bluing treatments for a firearm;
e) Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a pre- threaded muzzle;
f) Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;
g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and
h) Manual loading or reloading of ammunition of .50 caliber or smaller.
Activities limited to the domestic sale or resale of firearms, the occasional assembly of firearms without drilling, cutting, or machining, and/or specific gunsmithing activities that do not improve the accuracy, caliber, or operations of the firearm beyond its original capabilities (as described above) are not manufacturing within the context of the ITAR. If you are not manufacturing, exporting, temporarily importing or brokering defense articles or services, you are not required to register with DDTC.
If you are not drilling/milling/cutting etc you may be a BFF to the ATF but not DDTC. I will get clarification.
A good example thoigh, handloading under .50 cal is not mfg according to DDTC but if you are in the business of making ammo the ATF says you are a manufacturer. DDTC says it has to be systymated to be a mfg.
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