That worked oh so well for the Crypto and the (Turkish grey-import) Sterling R9, look where they've ended up after being sold without FRT entries.An FRT is not a requirement to make a sell guns in Canada.
Modifying the Renegade at this level is basically remanufacturing like many others have said, with the upper half of the Renegade being the serialized firearm. Also comparing this to the Pederson device feels shallow since that's a (rare and scarcely ever seen) drop-in conversion and not a permanent modification to the firearm as a whole, just to make a case for changing action types "legally".
If Lockhart *really* wanted to keep their nose clean they could just make another semiauto themselves from scratch, much like the Crypto, instead of overhyping a conversion service of dubious legality and overhyping their own straight-pull/lever/pump rifle likely to be DOA like the Crusader PND is currently perceived