Many small businesses involved in gunsmithing are surprised when informed that they are required to register with the Directorate of Defense Trade Controls (DDTC). They don’t see how their activities make them a manufacturer. Guidance from DDTC in July, 2016 sought to clarify what qualifies as a manufacturer.

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;

h) Blueprinting firearms by machining the barrel

If you are producing parts or modifying firearms, you are most likely considered a manufacturer and are required to register. If you are unsure of whether you need to register, it is recommended that you submit an advisory opinion request to DDTC.