The State Department’s Directorate of Defense Trade Controls (DDTC) has issued a letter setting forth more executive gun controls–guidelines for gunsmiths to register with the DDTC and pay fees requisite to that registration.

The registration requirement is presented as being based on the International Traffic in Arms Regulations, but the Arms Export Control Act and the Gun Control Act also play a role.

The DDTC’s letter sets forth certain activities that correspond with “manufacturing” and require registration/fees if being done by a gunsmith. The letter also lists a number of activities that a gunsmith can do that do not require registration. The combination of the two–register for this; don’t register for that–is cryptic at best and resulted in the National Shooting Sports Foundation (NSSF) issuing a statement, which Breitbart News possesses, in which NSSF observed the DDTC’s guidelines have “created considerable and understandable confusion and concern among gunsmiths and gun owners.”

For example, the DDTC lists registration requirements thus:

Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under §122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register.

DDTC goes on to say a gunsmith does not need to register/pay fees for activities such as “occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining,” “firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation,” “repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation,” and more.

However, registration/fees are required for “use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms,” “modifications to a firearm that change round capacity,” “production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors),” and more.

Both lists, for where registration is or is not required, are elaborate, leading the NSSF to observe that “many of the activities DDTC claims require registration constitutes gun smithing and is not manufacturing under any reasonable dictionary definition of the term. DDTC’s position is similar to claiming an auto mechanic who fixes your car is a car manufacturer.”

Gunsmiths who are required to register will pay a fee of approximately $2,250.

AWR Hawkins is the Second Amendment columnist for Breitbart News and political analyst for Armed American Radio. Follow him on Twitter: @AWRHawkins. Reach him directly at awrhawkins@breitbart.com.