From NRA:

In July, we reported on an ill-advised attempt by the Directorate of Defense Trade Controls of DOS (DDTC) to “clarify” who is a regulated firearms “manufacturer” for purposes of the Arms Export Control Act and its implementing rules, the International Traffic in Arms Regulations (ITAR).

As we noted in that report, DDTC’s “guidance” document creates far more confusion than clarity and threatens to chill lawful behavior and put small commercial gunsmiths who cannot afford ITAR’s heavy compliance costs out of business.