We need to understand where 922 (r) is "coming from." For whatever reasons, Congress, in the 1968 law, banned the import of firearms that were not "sporting". But they didn't ban the manufacture of such firearms in the U.S. (A little lobbying by the gun manufacturers, folks! And remember that an evil imported milsurp rifle was used to kill JFK!)
But the purpose of the law, to protect U.S. gun makers, would be defeated if companies were allowed to import foreign parts and assemble the guns in the U.S. So they specifically banned the use of IMPORTED parts to ASSEMBLE, in the US, guns that if assembled elsewhere could not be imported.
That is what 922 (r) is all about. I can't read anything into it that says you can't replace a worn sear in a legally imported SKS with a new sear, no matter where the new part is made. And I can't read anything into it that says you can't assemble from any parts, a gun identical to a gun that can be legally imported. Or that says you can't manufacture in the U.S. a gun identical to a banned gun using U.S.-made parts. Or anything that says you can't shoot a legally imported gun no matter where the parts came from.
It is only when you decide to assemble, from imported parts, or a combination of imported and domestic parts, A GUN THAT CANNOT BE LEGALLY IMPORTED, or to alter a legally imported gun in such a way that the resulting gun could not be legally imported, that 922 (r) and the parts count comes in.
Briefly, it is not HOW you put a gun together, it is WHAT you put together; it is the result that brings the gun under 922 (r).
(The issue of originality of parts to preserve collector status is totally irrelevant.)
Jim
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