[Webleymkv]

922(r) is a rather complicated subject with many facets that you need to understand. The first thing that you need to understand is that 922(r) applies only to firearms imported after 1989 that would be banned from importation under 925(d)(3). In 1989, the ATF ruled that "semi-automatic assault weapons" did not meet the "sporting purpose" test of 925(d)(3) and were thus no longer legal to import. The ATF ruled that any one of seven features on a semi-automatic rifle would constitute a "semi-automatic assault weapon" and thus not importable under 925(d)(3). These features include:

1. Folding/telescoping stocks
2. Separate pistol grips
3. Ability to accept a bayonet
4. Flash suppressors
5. Bipods
6. Grenade launchers
7. Night sights.

Subsequently, in 1997, the ATF re-evaluated the 1989 ruling at the direction of President Clinton. In 1998, the ATF further ruled that rifles which were modified to possess none of the "assault weapon" features specified by the 1989 ruling but could still accept "large capacity magazines" originally designed and produced for the military rifles from which said firearms were derived also no longer met the "sporting purpose" test and thus could no longer be imported. The most obvious example of this, and likely the firearm at which this re-evaluation was aimed, is the Norinco Mak-90 which has none of the 1989 "assault weapon" features but can still accept standard AK-47 magazines.

So, 922(r) applies to your Saiga only if you modify it in such a way that would make it unimportable under 925(d)(3) if so-configured from the manufacturer. Where we have something of a grey area is the use of aftermarket "large capacity" magazines in an unmodified Saiga. Because SGM Tactical and Pro-Mag Saiga magazines were not originally designed, developed, or manufactured for military AK rifles, an argument could be made that their use in an unmodified Saiga is legal since magazine capacity was not a listed feature in the 1989 ruling. However, because the intent of the 1998 ruling was obviously preventing "large capacity magazines" from being used in imported rifles, the ATF could very well take a dim view on the use of aftermarket "large capacity magazines" in an unmodified Saiga. The safest way to use aftermarket "large capacity" mags in a Saiga is to go ahead and do a 922(r) conversion.

Now, the thing to remember about 922(r) is that it is neither the number of U.S.-made parts nor the total number of foreign-made parts that really matters, but rather the number of foreing-made parts from the ATF's list. That list includes the following 20 specific parts:

1. Frames, receivers, receiver castings, forgings, or castings
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

Now, an unmodified Saiga has 14 of those 20 parts but, because it has no "assault weapon" features, comes with 10-round magazines, and cannot accept standard AK mags is not subject to 922(r). However, if you add any of the "assault weapons" features or, arguably, use >10-round magazines, it becomes subject to 922(r). The specific parts from the list that an unmodified Saiga has, and thus you need to replace four of for a 922(r) conversion, are numbers 1, 2, 4, 6, 7, 9, 11, 12, 14, 15, 17, 18, 19, and 20. Also note that adding a part from the list that your rifle did not originally have such as a pistol grip or flash hider is also considered for 922(r) and thus effectively raises the number from the 14 for an unmodified Saiga. The most common method for a 922(r) conversion which still allows the use of imported magazines is to add a U.S.-made pistol grip, buttstock, trigger, hammer, and disconnector (five parts since the Saiga did not originally have a pistol grip).

In you case, simply replacing one of the 14 parts without adding any that the rifle didn't originally have you make you 922(r) compliant with U.S.-made mags as the mags count for three parts (magazine body, follower, and floorplate). Also, so long as the part you replace doesn't add any of the ATF's "assault weapon" features you can still use the stock 10-round mags as, when they are installed, 922(r) would not apply. Your idea of replacing the handguards would work so long as you do not attach a forward pistol grip, bayonet, bipod, night sights or anything else that would run afoul of the 1989 ruling to said handguard or any other part of the rifle. If you wanted to make the rifle 922(r) compliant with foreign-made "large capacity" magazines without having to replace the original buttstock, you could do so by replacing the hadguard, hammer, disconnector, and gas piston (only the original trigger will work without installing a pistol grip).