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Your AO is giving you really bad advice. Police consider the upper and/or lower to be the 'action', so they both require import permits. This is stated on the police website.

A permit is not...

No one needs to sign section 8 "the not allowed to export bit".
Needing an import permit isn't a Brownells thing. The US State Department require it (or a letter) as part of the export process.
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The DSP-83 doesn't need to be signed by the Ministry of Foreign Affairs. You only need to complete sections 3, 4, 5 and 7. The State Department won't accept your word that an import permit is not...