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[r6533]

Questions answered.

[ojisan]

1. Yes.
2. Gunsmith / manufacture full license needed for barrels, cylinders, frames, receivers, bolts, slides. Other parts generally ITAR is required, especially if the part is for something like an AR / AK, in this case the sights would be considered military equipment. If these could only fit sporting type shotguns then you might be able to avoid ITAR. But .gov will make the decision.
3. They pretty much want ITAR on everyone. Look at a Brownell's catalog, almost everyone there is ITAR registered.

[franklinarmory]

ITAR is required of manufacturers, but it is not required of gunsmiths. So if you are simply installing components, you will not need to register. You need to be registered the moment you start making and selling gun parts unless you petition to have your parts exempted. I have never tried the exemption, but I do know there is a process. If you only have a few SKUs, it might make sense for you to try that.

It's ironic that ITAR is required on sights and accessories when he certain foreign countries can flood the market with cheap options.