So basically any real gunsmith such as Jeff or Anyone that threads or profiles a barrel or installs a breech plug in a CF gun is screwed and has to register.
This really really really SUCKS!
As in all laws interpretation is the key, someone will find a loop hole if one is in fact needed:
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.
The term “manufacturing” is not defined in the ITAR. In order to determine whether a firearmsrelated
activity constitutes manufacturing for ITAR purposes, DDTC applies the ordinary,
contemporary, common meaning of the term. Likewise, DDTC applies the ordinary,
contemporary, common meaning for “gunsmithing,” which traditionally has broadly included
designing, making, or repairing guns. Not all firearms (as defined by ATF regulation) are
“defense articles” under the ITAR, however, and not all activities involving assembly of and
repairs to firearms qualify as manufacturing for ITAR purposes. DDTC has found that many
traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and,
therefore, do not require registration under the ITAR, particularly where such activities do not
require cutting, drilling, or machining and do not improve the accuracy, caliber, or operation of
the ITAR-controlled firearm beyond its original capabilities.
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