No, as long as it's not part of your regular business. Read number 6
ATF Online - Firearms - Frequently Asked Questions - Manufacturers
The government is trying to squeeze out the little man. The ATF just changed their "view" on what a manufacture really is, so that small gunsmiths/shops with a type 1 FFL need to really get a manufacturer license to do anything. But, then they have to pay the ITAR tax which is huge.