Theoretical questions...
1) At what point does one need to have a Type 07 licenses, v. a Type 01? Let's day a gun shop owner with a Type 01 license receives a lower or a complete AR, but decides to put a new or different upper on the lower. Does that cross the line into manufacturing?
2) Perhaps a Type 07 FFL holder receives a Colt lower, and wants to put an upper on that lower, and fully assembles the upper with barrel, etc. Does he/she now need to mark the lower, or must the FFL 07 holder get a variance if he/she does not want to mark-up that nice Colt lower? If a variance is needed, would Colt even pick up the phone to respond to a small FFL holder?
3) Now, assume a Type 07 FFL holder who is invovled in assembling parts. No manufacturing is taking place, but has some parts manufactured, by other sub-contractors. Maybe sights or gas blocks, or barrels, etc., made to his specs (as many barrels are). Must the 07 FFL holder also register for ITAR ?
4) What safeguards must a Type 01 or Type 07 FFL holder take, if not registered for ITAR, to make sure that he or she is doing business, selling only to US Persons ? (also asked in another thread)
Thanks, follks. Noob questions from a non-FFL holder who is contemplating...