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Regarding my earlier post; the DOS intent is to redefine gunsmith/manufacturer and to redefine firearm. Historically the rebarreling of firearms (cutting threads, rechambering, recrowning etc.) has been considered a traditional gunsmithing activity. Blueprinting an action has always been a gunsmithing activity.
If you read the 22 July 16 letter, you will see a common theme: things that enhance capability. So, improving the current firearm.
Traditionally gunsmiths have been the go to folks to enhance your firearms capability whether it be putting a Shilen or Heart barrel on your favorite deer rifle, making the action smoother/more reliable, recrowning the muzzle, or correcting headspace. The DOS has now redefined these activities as 'manufacturing'. Meaning that your gunsmith who has a 01 license, must now apply for and obtain a 07 manufacturing license from the ATF, then register with DDTC as a manufacturer, pay $2400 annually and deal with all the administrative BS from DOS as well as ATF.
Want a custom myrtle wood stock for you Winchester model 70? Guess what, your gunsmith now needs to be registered with ITAR.
Additionally, if you read the US Munitions list, you will see that the only exceptions are sporting shotguns with barrels greater than 18 inches and muzzle loading black power rifles. Ever since the GCA of 1968 firearms manufactured prior to 1898 had been considered non-firearms and exempt from the GCA of 1968. The DOS make no mention of exempting Antique firearms.
I’ve talked to a few gunsmiths, and they are seriously weighing their options as to comply or shut the lights off.
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