Until then the existing interpretation seems to me to mainly impact occasional FFLs or hobbyists. Any manufacturer or any shop large enough to have prominent visibility in the industry has likely been registered since day one.
Up until this point I could live with your rational. I sincerely doubt that "any shop large enough to have prominent visibility in the industry ha likely been registered since day one." Manufacturer's (i.e Remington, Browning, Smith & Wesson, Springfield, et al) - yes; independents - no.
From DDTC's web site - "The U.S. Government views the sale, export, and re-transfer of defense articles and defense services as an integral part of safeguarding U.S. national security and furthering U.S. foreign policy objectives. The Directorate of Defense Trade Controls (DDTC), in accordance with 22 U.S.C. 2778-2780 of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130), is charged with controlling the export and temporary import of defense articles and defense services covered by the United States Munitions List (USML)."
By their own admission they are charged with "controlling the export and temporary import of defense articles and defense services covered by the United States Munitions List (USML)."
If you read the DDTC statement of July 22, 2016, you see a myriad of contradiction. It was written by an idiot. First they state - "DDTC has found that many – but not all - traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and, therefore, do not require registration with DDTC."
Then they go on to define or state processes that are the vary core of many gunsmith's operations, as manufacturing.
DDTC Letter, 22 Jul 2016 Digging a little deeper you'll find find that under the USML (Part 121) that there is NO mention of controlling any act of gunsmithing.
USML Part 121 IMHO, the State Department and DDTC have over-stepped their bounds. The State Dept and DDTC control EXPORTS, NOT the act of gunsmithing. If a firearm has been machined, or otherwise improved by a manufacturer or gunsmith to the point the DDTC believes that it should not be exported, then don't approve the export. Don't step on or crush the livelihood of gunsmiths, or the enjoyment of a hobbyist.
The whole subject of the DDTC's reach and opinion is a ploy by the current administration to assert gun control by another means. Take the time to read the above links. Re-read them. Compare the information contained in each, and think about it. I'm not a lawyer, or a para-legal, and play neither on TV. But there is enough contradictory information in the above links that I could write a Master's Dissertation from it, and good lawyer could make a strong case in a court.
