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that's where the "relic" part of C&R comes in. Otherwise, if it's newer than 50, it has to be on the list as a "curio"
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That's not really the whole story. In a nutshell, here's what qualifies a gun for C&R status:
- Listed in the ATF book or added to the list on an ad-hoc basis by an ATF letter (effectively the same thing); OR
- At least 50 years old; OR
- Certified by certain experts as being of particular historical interest; OR
- Specifically associated with a notable person and/or event.
AFAIK category #4 is generally reserved for individual firearms, e.g. an otherwise run-of-the-mill gun that wouldn't be particularly special except that a former U.S. President owned it, and you have a signed letter proving it. A more grim example would be the Colt Cobra that Jack Ruby used to shoot Lee Oswald.