Correct, but non-exporting 07FFLs were already required to register with ITAR even though they had no export event. I lack faith that they will make the correct decision that ITAR registration is no longer required because products are subject to EAR given past interpretation. The logic will be "How can you know that it is EAR with out being up to speed/date/trained on ITAR and proving that requires ITAR registration. How can you do a CJ on the product and rule EAR w/o know ITAR so you must be ITAR registered." See? I can make the bogus arguments for them on why ITAR registration tax collection is still required