Found it:
http://pmddtc.state.gov/compliance/Appl ... blish).pdf
Here's the applicable parts:
2. Registration Required – Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:
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; and
h) Blueprinting firearms by machining the barrel.
"machining, cutting, or drilling" applies to rechambering.
"Use of any special tooling..." is certainly vague enough to snag unsuspecting people.
How about "The systemized production of ammunition". If you have a turret reloader, that's pretty systemized.
It does say:
"Persons who do not actually manufacture ITAR-controlled firearms ... need not register with DDTC – even if they have an FFL from ATF."
but all that has to happen is that they re-define "ITAR-controlled firearms" and it all goes out the window.
Steve