You really think reloading for free means he's "in the business of selling or distributing reloads for the purpose of livelihood and profit."?
Doesn't sound like a very good way to make a living to me.
He can reload for other people all he wants as long as he's not doing it for profit.
From the ATF FAQ:
Q: Is a person who reloads ammunition required to be licensed as a manufacturer?
Yes, if the person engages in the business of selling or distributing reloads for the purpose of livelihood and profit. No, if the person reloads only for personal use.
[18 U.S.C. 922(a) (i) and 923(a), 27 CFR 478.41]