And that is a going to be a huge burden for a small gunsmith operation. Attorneys who have in-depth ITAR knowledge and experience are expensive.
In a previous professional life, I went through ITAR training once a year, and I coded every product the business made for export, so that FedEx would ship it. Every year we were told something that contradicted the previous year's training. It is a complicated morass of confusing, contradictory stuff that the attorneys could not even clearly parse on a consistent basis.