922 compliant?

[DE Shooter]

I bought an 03 EAA Saiga 223/556...sporter. Like NIB...almost. Front sight so canted, couldn't be zero'd. I removed it and replaced it with made in USA FSG with 24mm threading. Put a made in USA AK74 muzzle break on too. Took Saiga stock off and replaced with USA stock/pistol grip setup. Have made in USA Surefire 30rnders and Bulg circle 10s adapted for Saiga.
1. Does the FSG or muzzle break of both have to be pinned or welded or both?
2. With the mags mentioned, am I legal?
3. Do I need to change the spring and follower in the Bulg mags?

I appreciate any info...I'm hearing conflicting reports from all directions, so I figured I'd try here. I've read several 922 compliant lists...am I to believe the entire law is based on imported parts? I also have a USA made fore grip...but am hoping to use for my x39 mod.

[raftman]

If you're gonna modify your Saiga in such a way as to render it no longer "suitable for sporting purposes" like using a "high capacity" mag, the bottom line is, no more than 10 of its countable parts may be foreign made. Here is a list of all possible countable parts as taken from the Saiga forum (http://forum.saiga-12.com). A Saiga rifle, as it comes out of the box has only 14 of the following, they're marked with a *


(1) Receiver *
(2) Barrels *
(3) Barrel extensions
(4) Mounting blocks, trunnion (rifles only)*
(5) Muzzle attachments (shotguns w/ threaded barrels only)
(6) Bolts *
(7) Bolt carriers*
(8) Operating rods
(9) Gas pistons *
(10) Trigger housings
(11) Triggers *
(12) Hammers *
(13) Sears
(14) Disconnectors *
(15) Buttstock *
(16) Pistol grips
(17) Forearms, handguards *
(18) Magazine bodies *
(19) Followers *
(20) Floorplates*

So, no matter what parts you add or switch out, or any of that, what matters is that in the end, that your rifle have no more than 10 countable parts of foreign manufacture.

[sectshun8]

Great explanation of that raftman... a Saiga might be in my near future and was curious of the same, thanks.

[Webleymkv]

In order to be compliant with a PG, a stock Saiga must have at least four of the 14 selected parts on a stock Saiga replaced with ones made in the USA (a stock Saiga doesn't have a PG so it doesn't count as replacing anything). A conversion to full AK configuration (stock and PG are two completely separate parts) usually involves a US made stock, PG, and Fire Control Group (trigger, hammer, and disconnector). From what you decribe, you're only compliant with the Surefire mags with 4 replaced parts (stock, mag body, follower, floorplate), but not with the Bulgarian mags since you only have one (stock). The pistol grip doesn't count as replacing an imported parts because a stock Saiga doesn't have one nor does the muzzle attatchment because there was no brake on the original gun either. Remember, the key is not how many U.S. made parts you have, but how many imported parts you don't have. You can have as many U.S. made parts as you like but if you've still got 11 or more imported parts on a "non-sporting" rifle it's still illegal.

Now, I'm not sure exactly what type of stock and pistol grip you have. Conversion to a true AK setup would require replacement of the trigger as it and the disconnector must be moved forward (most people just replace the entire FCG as all three pieces often come as a package and counts as three parts). If this is the setup you have, I'd reccomend using a U.S. mad FCG (I've been happy with the single hook Tapco G2 FCG I used in my conversion), as it's one of the least expensive replacements and would bring you imported parts count down to 10 (compliant) even with Bulgarian mags. If you're using one of the setups that simply bolts on in place of the sporter stock, things get a bit more interesting. Because the trigger is still in the farther rearward sporter position, a U.S. made AK trigger would not work and it would be IMHO, too much trouble to replace the hammer and disconnector without doing a full conversion. The only other compliance parts that can be relatively easily replaced would be the front handguards and gas piston. Even if you replaced both of those, you'd still have to replace at least one mag part to make it compliant with imported mags.

[DE Shooter]

raftman and webleymkv,
Thankyou both very much. I will base any additional mods on your excellent info. I didn't think the Bulg mags would be legal without US made additions.

Here's one for the road...if you care to venture an opinion:

If I take a Saiga part off and radically modify it's shape and add US made parts, is it still considered an imported part. For example...I take the stock Saiga fore-stock off. Cut it to a shape I like, ventilate it and customize it with US made additions like over, under and/or side rails...or maybe a US made quick release bipod or something else...

Will Uncle Sam say its an imported part...because it was...or is it a made in USA part...because it is now made in the USA??? Has any legal president ever been set?

[Webleymkv]

If I take a Saiga part off and radically modify it's shape and add US made parts, is it still considered an imported part. For example...I take the stock Saiga fore-stock off. Cut it to a shape I like, ventilate it and customize it with US made additions like over, under and/or side rails...or maybe a US made quick release bipod or something else...

Will Uncle Sam say its an imported part...because it was...or is it a made in USA part...because it is now made in the USA??? Has any legal president ever been set?

That's a tricky one but I'd err on the side of caution and assume that it would still be considered an imported part. Here's an explanation and text of 922r and certain other laws.

http://www.gunsnet.net/forums/showthread.php?t=40375

Assuming we're talking about a bone-stock Saiga, you could still make certain modifications to the handguards. 922r only applies if the firearm in question is modified in such a way that it would be unimportable under 925(d)(3). The features specifically listed are as follows

These characteristics include the ability to accept a detachable magazine, folding/telescopic stocks, seperate pistol grips, ability to accept a bayonet, flash suppressors, bipods, grenade launchers, night sights. It was decided that any of these military features, other than a detachable magazine, would make a semiautomatic assault rifle not importable.

According to that, the only one of the mods you suggested that would require a full conversion would be the bipod. However, you would need to be careful what you put on those rails as a foreward PG, grenade launcher, night sights, or any of the other "assault weapon features" would require 922r compliance.

Honestly a full conversion makes things a lot easier as you can do basically whatever you want to the rifle afterwards so long as any "special" part added is U.S. made and it doesn't run afoul of and NFA regs.

[SevenSixTwo]

This is interesting, I was wondering something about my saiga to. My 7.62x39 is still "out of the box" completely unmodified(stock). I wanted to replace the forearm with a us made tapco galil style forearm and leave everything else alone. Would this be legal? As I do not wish to change it to assault configuration. Just leave the rifle as I bought it with a new style of forearm?

[Webleymkv]

Disclaimer: I'm not a lawyer, I don't play one on TV, and I didn't stay at a Holiday Inn Express last night. My opinion is worth every penny you paid for it.

As far as I can tell, a Tapco Galil forearm and nothing else would not put you in violation of 922(r) as you are not adding any of the features described in 925(d)(3).

The only real grey area that I've found is the use of aftermarket high capacity magazines in an unconverted Saiga. Some (myself included) will say that this is OK so long as you don't add any other 925(d)(3) features as a detatchable magazine was specifically excluded from the list of unimportable features and no mention of specific mag capacity is made in either 922(r) or 925(d)(3). Others will say that a high cap mag in an unmodified rifle is a violation of 922(r) pointing to the ban of guns like the Mak90 because the ATF determined their ability to accept standard AK mags made them "unsporting."

The good news for you is that if you replace the handguards with the Tapco ones and use U.S. made high capacity mags like surefires, you have 4 compliance parts and thusly the magazine debate is a moot point as you'd be compliant anyway.

[SevenSixTwo]

That seems justifiable. Keep it in "sportsman" configuration and no further steps are required. I wouldn't use hi-cap mags anyway as that is in violation of our local California laws. We are limited to 10 rnd capacity on all guns, and while it sucks...I'm actually ok with it. I just wanted to change the look of the forearm to suit my tastes.
It wouldn't make sense anyway to restrict a single customization as the saiga comes stock with more than 10 import parts anyway. If it wasn't legal to own, why would a ffl dealer sell one to a uninformed citizen? Wouldn't they be violating the law by selling them?

[Webleymkv]

It wouldn't make sense anyway to restrict a single customization as the saiga comes stock with more than 10 import parts anyway. If it wasn't legal to own, why would a ffl dealer sell one to a uninformed citizen? Wouldn't they be violating the law by selling them?

The key to understanding 922(r) is also understanding 925(d)(3) upon which it's based. 922(r) only applies if the firearm is imported and has a feature that, if equipped that way from the factory, would have barred it from importation under 925(d)(3). The list of unimportable features under 925(d)(3) is as follows:

These characteristics include the ability to accept a detachable magazine, folding/telescopic stocks, seperate pistol grips, ability to accept a bayonet, flash suppressors, bipods, grenade launchers, night sights. It was decided that any of these military features, other than a detachable magazine, would make a semiautomatic assault rifle not importable.

Adding any of those features besides a detatchable mag would make an imported firearm subject to 922(r). Your Tapco handguards, however, do not add any of those features so 922(r) does not apply. It's not about how many modifications you make, it's about what modifications you make. You can make as many modifications to your Saiga as you like and so long as none of them are unimportable features under 925(d)(3) then 922(r) will not apply. However, if you make even one modification that would be unimportable under 925(d)(3), then 922(r) applies and you must replace the appropriate number of the specified parts with U.S. made ones.

Really, most of this probably doesn't make much difference for you as most of the features deemed unimportable under 925(d)(3) are probably also banned by your state's AWB.