I am going to have to retract what I said in my first post. ATF is lumping cartridges cases, bullets, powder and primers under ammo manufacturing, Exceptions for lead shot, shot shells, and BP bullets. I would suggest you call the Firerams Techical branch over in Martinsburg WV. Am on the road, do not have their number with me, but if you call local ATF office, they should have phone number. Regulation is over around 923(a), 27 CFR 478.41. My bad.
What we have here is... failure- to communicate.