Yes, and that is why the first T97 reference hearing is so important.
It will provide a starting point to establish a more detailed definition than exists at present. Case law precedents on the topic are few and far between.
This is why whoever gets to court first had best have all their ducks in a row.
If the RCMP can demonstrate that conversion is extremely easy, and this is what they seem to be claiming, it is unlikely that a judge who is not particularly knowledgable about firearm design is going to disagree with them.