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Old July 29, 2008, 12:12 AM   #1
Yithian
Senior Member
 
Join Date: June 7, 2007
Location: Texas
Posts: 719
To Help Clear Up 922(r) Compliance

Quote:
Originally Posted by ISC
Here is the actual subsection from the ATF website:

http://www.atf.gov/firearms/building_a_firearm.pdf

“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
the…[GCA]…Section 925(d)(3)…as not being particularly suitable for or readily adaptable to
sporting purposes….”
Also, 27 C.F.R. § 478.39 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…..

(b) The provisions of this section shall not apply to:
(1) The assembly of 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 such rifle or shotgun
for the purposes of testing or experimentation authorized by the Director under the provisions of
[§478.151(formerly 178.151)]; or (3) The repair of any rifle or shotgun which had been imported
into or assembled in the United States prior to November 30, 1990, or the replacement of any
part of such firearm.

(c) For purposes of this section, the term imported parts [tabulated below] are:
(1) Frames, receivers, receiver
castings, forgings, or castings.
(2) Barrels.
(3) Barrel extensions.
(4) Mounting blocks (trunnions).
(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) Floor plates.

As a result of a 1989 study by the U.S. Treasury Department regarding the importability of
certain firearms, an import ban was placed on military-style firearms. This ban included not only
military-type firearms, but also extended to firearms with certain features that were considered to
be “nonsporting.”
Among such nonsporting features were the ability to accept a detachable magazine;
folding/telescoping stocks; separate pistol grips; and the ability to accept a bayonet, flash
suppressors, bipods, grenade launchers, and night sights.
Please note that the foreign parts kits that are sold through commercial means are usually cut up
machineguns, such as Russian AK-47 types, British Sten types, etc. Generally, an acceptable
semiautomatic copy of a machinegun is one that has been significantly redesigned. The receiver
must be incapable of accepting the original fire-control components that are designed to permit
full automatic fire. The method of operation should employ a closed-bolt firing design that
incorporates an inertia-type firing pin within the bolt assembly.
Further, an acceptably redesigned semiautomatic copy of nonsporting firearm must be limited to
using less than 10 of the imported parts listed in 27 CFR § 478.39(c). Otherwise, it is considered
to be assembled into a nonsporting configuration per the provisions of 18 U.S.C. 925(d)(3) and is
thus a violation of § 922(r).
I am going to convert a Saiga223 this weekend.

(ignore the logo, I stole the photo for visual aesthetics)

What does one need to understand to comply with 922(r)?
I'll tell you the 'safe' way to read it.
Also, there is a stink concerning the magazine since it was imported with a removable magazine.
I say, why give a DA any excuse, treat the firearm as if it fell under that other "grey" law.

This is the reason why we have to follow the "law" when converting...
Quote:
“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
the…[GCA]…Section 925(d)(3)…as not being particularly suitable for or readily adaptable to
sporting purposes….”
An AK is illegal to import.
I have the Saiga and want to convert it to the original AK format. ie. pistol grip.
I also want to be able to use the original magazine with the rifle and stay compliant.

Quote:
Full list:
(1) Frames, receivers, receiver
castings, forgings, or castings.
(2) Barrels.
(3) Barrel extensions.
(4) Mounting blocks (trunnions).
(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) Floor plates.
Quote:
The Saiga223 has:
(1) Frames, receivers, receiver
castings, forgings, or castings.
(2) Barrels.
(3) Mounting blocks (trunnions).
(4) Bolts.
(5) Bolt carriers.
(6) Gas pistons.
(7) i* Triggers.
(8) i* Hammers.
(9) i* Disconnectors.
(10) Buttstocks.
(11) Forearms, handguards.
(12) m* Magazine bodies.
(13) m* Followers.
(14) m* Floor plates.
Note: The rifle does not come with a pistol grip, and therefore, it is not in the list of parts. But it is included in the full list.
Once I add the pistol grip, the rifle will have 15 parts from the full list.
If I add a US made pistol grip, then I wont have to worry about that being a part counted against me.

Of the list of 20 items that must not be greater than 10 parts foreign, the Saiga is imported with only 14 parts.
So, 14 parts are foreign, but the firearm is legal as-is.
To legally own a converted Saiga, ie. an AK, I must swap at least 4 parts for US made parts.

The Fire Control Group (FCG) [noted with i*] is an easy three parts.
The Magazine [noted with m*] is another easy three parts.
Why not just swap those parts with the pistol grip and call it finished?
Well, what happens when I want to use the original magazine?
Once I insert the original magazine, or any non-"US made" magazine, the rifle is again "illegal".
I have re-added 3 parts from the list.
So, I must ignore the 3 parts noted 'm*' for my compliance.

Here is the parts I choose...
AK-47 Adjustable Military Trigger System

This is my FCG with 3 parts US made. I have this in-hand.
Very sturdy and built very well. I already have one of these, in larger version, for my Saiga308. It is sweet compared to the stock FCG.

For the buttstock...
CAA, 6 Position CBS Stock with Aluminum Tube for AK47 Stamped Receiver

I was waiting for the Tan colored stock for 3 weeks.
I got tired of waiting. Now it is OD Green with a black tube.
Delivery is this week.
I need to inspect it when it gets here. I need to verify where it was manufactured.
If it isn't US made, I will be stuck using only the US made magazines until I get a replacement.

For the pistol grip...
aka, part 15.
CAA, UPG47

This will be Black. It is delivered this week.

For the forearm/handguard...
TAPCO, Saiga Galil Style Handguard (OLIVE DRAB)

It is also a part on the list. It is to be delivered this week as well.
I don't have to swap this part out to comply, but look at the 223 photo above.
The barrel is too short for the full length foregrip, IMO.

Just for kicks, I ordered a cheek rest...
CAA ACP

It is hard to make out in this pic, but it is the black aparatus on the tan stock.

So, lets count my parts...
Quote:
1: FCG trigger
2: FCG hammer
3: FCG disconnector
4: Buttstock (assuming US made part)
5: Forearm/handguard
Quote:
14 - 5 = 9
I did add the pistol grip tho, didn't I.
But it is Israeli made.
so, ...

Quote:
15 - 5 = 10
10 parts out of 20 listed is within the 10 parts limit.

I will have a AK chambered in 223Rem that complies with the law,
... whether it needs to comply with the law or not.
Better Safe than Sorry.
(Personally, I feel the "law" is against the 2nd Amendment, but I choose to avoid the headache)



I and ATTT will be working on it this Sat. Hopefully.
We intend on documenting its conversion.
I may post pics.

For those wantng to know the process...
http://www.cross-conn.com/Saiga_Conv...ex.htm#WARNING!
__________________
Pondering the differences, terminally, between the V-Max and the A-Max.

Last edited by Yithian; July 29, 2008 at 06:25 PM. Reason: adjustment of data for grip manufacture, thanks Coomba
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