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The Saiga 12 as imported then wouldn't be affected, but as modified would be?
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Not likely.
I've been doing more reading on this, and my guess is 922r and its parts count will apply to the S12; it's discussed a bit here and there.
Thing is, as it is imported, the S12 is perfectly legal, since it is "sporting." If you make it nonsporting through a conversion, you need to have 10 or less imported parts. The S12 has about 13, maybe 14 (if threaded for chokes), parts as-is (according to the usual ATF count). Most conversions would mean swapping out no less than 5 parts (trigger group is 3 parts, plus the buttstock and pistol grip). Use US made mags, that's 3 more.
Basically, use a US made trigger group and stock/pistol grip, and you're fine. Mine currently has 7 US parts swapped out (the 5 I mentioned, plus the handguard and muzzle device), so either way I'm fine.
Here's a bit of a discussion on this, and from what I can tell, this will be nothing new for us.