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Thread: 18 USC 922r Compliance

  1. #1
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    18 USC 922r Compliance

    For those who get into the world of battle rifles - particularly AK-style - you're going to find yourself having to deal with Federal regulations. Specifically, compliance with 18 USC 922R.

    There's lots of debate about what is and is not covered under 922R. I am not a lawyer, but I'm going to present my layman's understanding and interpretation of the compliance requirements. These are my opinions only -- and I don't encourage anyone to take a legal stand based on them.
    What is 922R?

    Title 18 of the US Code (18 USC), Chapter 44 Section 922 provides guidance on unlawful acts as they relate to firearms. You can read the text of the law by clicking here.

    Section 922 Paragraph R states:
    "It shall be unlawful for any person to assemble from imported parts any semiautomatic rifle or any shotgun which is identical to any rifle or shotgun prohibited from importation under section 925(d)(3) of this chapter as not being particularly suitable for or readily adaptable to sporting purposes except that this subsection shall not apply to--
    (1) the assembly of any such rifle or shotgun for sale or distribution by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
    (2) the assembly of any such rifle or shotgun for the purposes of testing or experimentation authorized by the Attorney General. "

    Most of us don't fall under those exceptions, so we are left to deal with meeting compliance with the law.

    "Sporting" Purposes
    Here's where things get a little tricky. Some rifles, such as the Saiga line, are imported for sporting purposes in a particular configuration. Generally, that means that do not incorporate any of the "evil" features that are typically associated with so-called "semi-automatic assault weapons". Chapter 27 of the Code of Federal Regulations Section 478.11 defines these SAWs. You can read the law, here. Specific examples of these features include:

    - High capacity (greater than 10 round for rifles, 5 rounds for shotgun) magazines
    - Pistol grip attachment
    - Folding buttstock
    - Muzzle device/attachment (to include a threaded barrel capable of receiving a device)
    - Bayonet lugs
    If your rifle or shotgun incorporates those features, it no longer is considered "suitable for sporting purposes".

    Assembling Semiauto Rifles and Shotguns
    If your rifle or shotgun is subject to 922R, you must now make sure that it is in compliance with the regulations governing the assembly of semiautomatic rifles and shotguns. That is covered in Title 27 Chapter 1 Section 178.39. Click here to see the text of the law. It states :
    (a) No person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph (c) of this section if the assembled firearm is prohibited from importation under section 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes.

    Paragraph (C) defines the following parts as "countable" under the law:
    (1) Frames, receivers, receiver castings, forgings or stampings *
    (2) Barrels *
    (3) Barrel extensions
    (4) Mounting blocks (trunions) *
    (5) Muzzle attachments *
    (6) Bolts *
    (7) Bolt carriers *
    (8) Operating rods
    (9) Gas pistons *
    (10) Trigger housings
    (11) Triggers *
    (12) Hammers *
    (13) Sears
    (14) Disconnectors *
    (15) Buttstocks *
    (16) Pistol grips *
    (17) Forearms, handguards *
    (18) Magazine bodies *
    (19) Followers *
    (20) Floorplates *
    These 20 items are referred to with the term "compliance parts". There are lots of other components that go into a weapon, but there are the only ones that count in terms of complying with the law.

    The 16 items marked with an asterisk are the parts that are generally found on a standard AK 47. The Saiga sporter rifle, as imported, does not have a muzzle device or pistol grip, so it has 14 countable parts. A Saiga shotgun has 13 countable parts (the trunnion is considered part of the receiver) - 14 if the barrel is threaded.

    So once you have done something to take your rifle or shotgun out of a "sporting" configuration, you must now make sure that your weapon has no more than 10 of these parts that are imported.

    Complying with 922R
    Now the trick is making your weapon compliant with the law. To do that, you will need to replace 3 to 6 of the existing parts with components made in the US.

    Here are the parts that most owners use to achieve 922R compliance:
    - Trigger
    - Hammer
    - Disconnector
    - Buttstock
    - Pistol grip
    - Handguard (upper and lower handguards on an AK only count as 1 compliance part)
    - Gas piston
    - Magazine parts (Note: body, follower and floorplate each count as 1 compliance part).

    So you can see that there are plenty of ways to achieve 922R compliance. Personally, I think relying on magazine parts to meet compliance is risky: if someone puts a foreign-made magazine in your weapon, you are now in violation of Federal law. Better to use the other parts for compliance and save the magazines as a "nice to have" compliance option.

    Calculating Compliance

    How you figure your compliance is up to you. Some people just count up the number of foreign parts and make sure it's less than 10. They don't consider any added parts if they are US-made. Personally, I prefer to start with the total number of compliance parts in my rifle/shotgun, then work backwards. To me it's safer, in the event that somewhere down the road you change out one part for another.

    Here's an example: I have a Saiga AK with pistol grip and muzzle device. Using the guidelines for countable parts, that gives me 16 parts. In order to be compliant, I must have at least 6 US-made parts in my rifle. My rifle has the following US parts:
    Trigger, Hammer, Disconnector, Compensator (muzzle device), Gas piston, magazine floor plate and magazine follower. That gives me 6 parts and means I am complying with the law.

    You'll notice that I broke my own rule about using magazine parts. That's because the buttstock and pistol grip I ordered turned out to be made in Israel, so they do not count as compliance parts. Unfortunately, they are so well-made and comfortable that I don't want to replace them! I also had the stock Saiga handguard customized, so it doesn't count for my compliance either.

    On my Saiga shotgun, I had 14 countable parts. In order to meet compliance, I installed the following US-made parts:
    Hammer, trigger, disconnector, buttstock, pistol grip, external choke (muzzle device), US-made magazines.

    That gives me a total of 9 US-parts -- and I only need 4. So while I have US mags to use, I'm not limited to them like I am with my Saiga rifle.

    Special Saiga Considerations

    The Saiga rifle is imported in a sporter configuration and thus is not subject to 922R compliance. That is....until you decide you want to use high capacity magazines! If you plan on doing a full AK conversion, then there's generally no problem -- the conversion parts (fire control group, buttstock, pistol grip) usually take care of compliance.

    Some people, though, want to keep the sporter configuration but use high caps - and that takes a little more creativity. There are 14 countable parts in the Saiga sporter (no pistol grip or muzzle device).

    Quick compliance parts include:
    - Handguard: TAPCO makes an AK-specific, Galil-style handguard (1 compliance part)
    - Gas piston: US-made gas piston (either AK 47 or AK 74) (1 compliance part)
    - Trigger: You can modify a TAPCO G2 trigger to work in the stock Saiga firecontrol group (requires grinding and cuttting) (1 compliance part)
    - Hammer: You can install a TAPCO G2 hammer in the stock FCG (1 compliance part)
    - Magazines: Complete US made mags (like ProMag or Thermold) or US followers and/or floor plates in foreign magazine bodies (1-3 compliance parts)

    Another popular "quasi conversion" is to use the ACE Saiga receiver block/pistol grip combo, like this. This gives you an AK-like grip/buttstock without having to move the FCG. Adding the pistol grip ups your parts count to 15. Since ACE equipment is US-made, the buttstock and pistol grip each count as 1 part. That means you only need three more (from the list above) to be compliant.

    Be aware that there is also a Russian-made version of the same block/grip combo. You can use it, but you then have to find 5 replacement parts to be compliant.

    There are also two kinds of Surefire magazines designed for the Saiga rifle. There are all-plastic ones that are US-made and count for compliance. The older versions are metal bodies, and although Surefire is a US company, the magazines use foreign parts and do not count for 922R compliance!
    -------------------------------------------------------------------------

    http://home.comcast.net/~navy87guy/home/922r.html
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  2. #2
    Off the meds swampdragon's Avatar

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    It may also be worth noting that a milled AK has one less part than a stamped AK. Therefor, a milled AK would likewise require one less US part to be compliant.

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    Administrator Krupski's Avatar

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    Quote Originally Posted by swampdragon View Post
    It may also be worth noting that a milled AK has one less part than a stamped AK. Therefor, a milled AK would likewise require one less US part to be compliant.
    Well I suppose I'll take 922(r) seriously when someone can tell me where my FCG or pistol grip was made......

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    Conributor 09/13 slamfire51's Avatar

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    Hmmm, I could have sworn 'Nut posted a Sticky on this. Guess not.
    There's no problem an AK can't solve...........


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    Administrator imanaknut's Avatar

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    I think what I posted is that 922(r) is now Title 27 / 478.39.

    http://ecfr.gpoaccess.gov/cgi/t/text...0.1.2.3.3.1.22

    Regardless, according to our wonderful government, as long as the imported rifle or shotgun you modified has 10 or less imported parts, all the children of the world are safe and secure. 11 imported parts and babies start dying, governments topple, and the universe will shatter as the time/space continuum gets torn to shreds.

    Oh, and whether you start counting your imported parts up to 10, or replace imported parts with US parts counting down from the original number, the result is the same.

  6. #6
    Off the meds swampdragon's Avatar

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    Quote Originally Posted by Krupski View Post
    Well I suppose I'll take 922(r) seriously when someone can tell me where my FCG or pistol grip was made......
    I didn't start the thread.
    Just tryin' to help out.

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    Senior Member Partisan1983's Avatar

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    The laws/regs on imported shotguns has changed.

    I can't remember what exactly though.
    Here's to pussy and gunpowder. One to live for, the other to die by.....Goddamn though, I do love the smell of 'em both !!!

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    Im new to this 922r thing, i just bought a mak 90 im going to change the dragunov plastic furniture with a pistol grip chinese wood stock set. after i do that im not going to be clompliant, My question is....WHO & WHERE are they going to check my gun to see if i have the proper parts count,when i go to the range? is the ATF going to come knocking on my front door wanting to do a parts count? LOL. and whos to say this so called chinese stock set wasnt made here in the good ol USA.

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    Conributor 09/13 slamfire51's Avatar

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    Quote Originally Posted by daytripper View Post
    Im new to this 922r thing, i just bought a mak 90 im going to change the dragunov plastic furniture with a pistol grip chinese wood stock set. after i do that im not going to be clompliant, My question is....WHO & WHERE are they going to check my gun to see if i have the proper parts count,when i go to the range? is the ATF going to come knocking on my front door wanting to do a parts count? LOL. and whos to say this so called chinese stock set wasnt made here in the good ol USA.
    The BATF is not ignorant on parts counts and where they were made.

    Who & where is anyone's guess. May happen today, or never. Most likely anywhere away from your house. Traffic stop, range check, etc.
    Better safe than losing your gun, gun owning rights, and a hefty fine.

    Of course, all this is up to you.
    There's no problem an AK can't solve...........


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    Administrator imanaknut's Avatar

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    In the for what it's worth department, but first my required disclaimer: I do not advocate the intentional violation of any law regardless as to it's sanity or stupidity.

    That out of the way, I have had ATF handle and fire one of my AK variants at the range, on my request, and neither took as long as a nano-second to see where the parts were made.

    And the required story. My daughter and I were having a good time at a local range. Her with an SAR-3 and me with an SAR-2. We were firing side-by-side and each emptied a 30 round mag on target as fast as we could. From a distance the two of us together sounded like one full auto. Guessing someone at the range isn't an American and called the feds. As we were shooting we noticed a couple of guys wearing matching jackets standing to the side watching us. I called them over and showed them first how softly the SAR-2 shoots by holding my supporting hand open under the lower handguard, and holding the rifle away from my shoulder. I pulled the trigger to show that there was almost no recoil, then asked if they would like to try it. One of them came over and took it, shouldered it as you normally would, aimed and pulled the trigger.

    The smile on his face was priceless as he turned to his partner and said, "you gotta try this". They are human, and after remarking about the lack of recoil, plus verifying that when they pulled the trigger it only fired one round, they left. They are not stupid and knew after watching that between the two of us, my daughter and I sounded like a full auto. After leaving we had a good laugh, but also were glad we didn't find out who didn't like the sound of full auto in the last lane.

    So what are the chances of you having your MAK-90 checked for compliance parts? To quote a friend of mine who is the person ATF goes to when they need firepower, as long as you don't run up to an agent and brag about "your hot-rodded weapon" they are not likely to care. Again, my disclaimer is still in force.

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    I have a Saiga AK with pistol grip and muzzle device. Using the guidelines for countable parts, that gives me 16 parts. In order to be compliant, I must have at least 6 US-made parts in my rifle. My rifle has the following US parts:
    Trigger, Hammer, Disconnector, Compensator (muzzle device), Gas piston, magazine floor plate and magazine follower. That gives me 6 parts and means I am complying with the law.

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    Forum Administrator Schuetzenman's Avatar

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    Quote Originally Posted by Liem Phan Thanh View Post
    I have a Saiga AK with pistol grip and muzzle device. Using the guidelines for countable parts, that gives me 16 parts. In order to be compliant, I must have at least 6 US-made parts in my rifle. My rifle has the following US parts:
    Trigger, Hammer, Disconnector, Compensator (muzzle device), Gas piston, magazine floor plate and magazine follower. That gives me 6 parts and means I am complying with the law.
    Actually you have 7 and 1 more US part than needed for compliance. Welcome to Gunsnet.

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    Conributor 09/13 slamfire51's Avatar

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    Quote Originally Posted by Liem Phan Thanh View Post
    I have a Saiga AK with pistol grip and muzzle device. Using the guidelines for countable parts, that gives me 16 parts. In order to be compliant, I must have at least 6 US-made parts in my rifle. My rifle has the following US parts:
    Trigger, Hammer, Disconnector, Compensator (muzzle device), Gas piston, magazine floor plate and magazine follower. That gives me 6 parts and means I am complying with the law.

    BTW, how are things in the Nam these days?
    I don't believe US gun laws apply there.
    There's no problem an AK can't solve...........


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