I'm just posting the laws and what my inspector told me on his way through my books. In my case I had a few form 2 machine guns built on premises and had never sold one on a form 3. No LE letters because those are NOT required when form 2'ing a MG unless its going out the door on a form 3. None of that was an issue. What was an issue was the ITAR. The examiner claimed, emphatically, that I needed to register with ITAR to keep my license. I have never seen anything in the US code to contradict his claim. Lots of 02/07's who claim they are exempt because they don't export but the state dept wording is pretty clear on the subject. If you have other info you'd like to share please do . You are right though. The state dept list of applicable munitions does not include sporting shotguns. The State Dept Category 1 list is pretty extensive though. I know this doesnt have a lot to do with the OP's question. I was an 02/07 SOT and the rules are different for plain dealers and I don't think the ATF gives a damn about type 7 FFL's without the Class 02 bump.
http://www.pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR_Part_121.pdf
"(a) The following articles, services
and related technical data are designated
as defense articles and defense
services pursuant to §§38 and 47(7) of
the Arms Export Control Act (22 U.S.C.
2778 and 2794(7)). Changes in designations
will be published in the FEDERAL
REGISTER. Information and clarifications
on whether specific items are defense
articles and services under this
subchapter may appear periodically
through the Internet Web site of the
Directorate of Defense Trade Controls.
(b) Significant military equipment: An
asterisk precedes certain defense articles
in the following list. The asterisk
means that the article is deemed to be
‘‘Significant Military Equipment’’ to
the extent specified in §120.7 of this
subchapter. The asterisk is placed as a
convenience to help identify such articles.
Note that technical data directly
related to the manufacture or production
of any defense articles enumerated
in any category that are designated as
Significant Military Equipment (SME)
shall itself be designed SME.
(c) Missile Technology Control Regime
Annex (MTCR). Certain defense articles
and services are identified in §121.16 as
being on the list of MTCR Annex items
on the United States Munitions List.
These are articles as specified in §120.29
of this subchapter and appear on the
list at §121.16.
CATEGORY I—FIREARMS, CLOSE ASSAULT
WEAPONS AND COMBAT SHOTGUNS
*(a) Nonautomatic and semi-automatic
firearms to caliber .50 inclusive (12.7 mm).
*(b) Fully automatic firearms to .50 caliber
inclusive (12.7 mm).
*(c) Firearms or other weapons (e.g. insurgency-counterinsurgency,
close assault
weapons systems) having a special military
application regardless of caliber.
*(d) Combat shotguns. This includes any
shotgun with a barrel length less than 18
inches.
*(e) Silencers, mufflers, sound and flash
suppressors for the articles in (a) through (d)
of this category and their specifically designed,
modified or adapted components and
parts.
(f) Riflescopes manufactured to military
specifications (See category XII(c) for controls
on night sighting devices.)
*(g) Barrels, cylinders, receivers (frames)
or complete breech mechanisms for the articles
in paragraphs (a) through (d) of this category.
(h) Components, parts, accessories and attachments
for the articles in paragraphs (a)
through (g) of this category.
(i) Technical data (as defined in §120.10 of
this subchapter) and defense services (as defined
in §120.9 of this subchapter) directly related
to the defense articles enumerated in
paragraphs (a) through (h) of this category.
Technical data directly related to the manufacture
or production of any defense articles
enumerated elsewhere in this category that
are designated as Significant Military Equipment
(SME) shall itself be designated SME.
(j) The following interpretations explain
and amplify the terms used in this category
and throughout this subchapter:
(1) A firearm is a weapon not over .50 caliber
(12.7 mm) which is designed to expel a
projectile by the action of an explosive or
which may be readily converted to do so.
(2) A rifle is a shoulder firearm which can
discharge a bullet through a rifled barrel 16
inches or longer.
(3) A carbine is a lightweight shoulder firearm
with a barrel under 16 inches in length.
(4) A pistol is a hand-operated firearm having
a chamber integral with or permanently
aligned with the bore.
(5) A revolver is a hand-operated firearm
with a revolving cylinder containing chambers
for individual cartridges.
(6) A submachine gun, ‘‘machine pistol’’ or
‘‘machine gun’’ is a firearm originally designed
to fire, or capable of being fired, fully
automatically by a single pull of the trigger.
NOTE: This coverage by the U.S. Munitions
List in paragraphs (a) through (i) of this category
excludes any non-combat shotgun with
a barrel length of 18 inches or longer, BB,
pellet, and muzzle loading (black powder)
firearms. This category does not cover
riflescopes and sighting devices that are not
manufactured to military specifications. It
also excludes accessories and attachments
(e.g., belts, slings, after market rubber grips,
cleaning kits) for firearms that do not enhance
the usefulness, effectiveness, or capabilities
of the firearm, components and
parts. The Department of Commerce regulates
the export of such items. See the Export
Administration Regulations (15 CFR
parts 730–799). In addition, license exemptions
for the items in this category are available
in various parts of this subchapter (e.g.
§§123.17, 123.18 and 125.4)."
