I think there may be an error in your logic....Category 1 does not describe firearms or components, it designates items as being defense articles or defense services. Category 1 is not a definition, it is a list.
126.5(6) indicates that firearms, close assault weapons and combat shotguns listed in Category 1 still need a license. It does not say that other items listed in Category 1 still require a license. Because category 1 is not a defintion, the exclusion provided for in 126.5(6) doesn't apply to the whole category.
And if your interpretation is in fact correct, I note 123.17(a) which exempts components and parts for Category 1(a) firearms except when those components are barrels, cylinders, receivers, frames or complete breech mechanism when the value does not exceed $100.
Plus, you may able to make a case that the sights are not manufacturer to military specifications. If they are not, they qualify for a different exemption.
I'm not an expert in ITAR though, and I just quickly read over these sections, so I could very well be wrong.
I borrowed that from another member who posted it; he did his digging after Brownells stated the limit had not changed. Brownells is sticking to the $100. Til I see evidence that they are wrong in their interpretation I will assume it is right. Hopefully it is wrong.




















































