Q: I was alerted to guidance released by the DDTC concerning ITARS this morning. We conduct re chambering operations as defined on page 3 section 2(f) and threading section 2(g) as well as others on the list. We have been conducting this business with our standard 01 Dealers license for years. It now seems we need to register with DDTC based on this guidance. What direction and clarification can you give use? Additionally has anything come out of ATF that points to them adopting these definitions of a manufacturer as defined by the DDTC guidance letter.
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