922(r) Compliance on a converted Saiga rifle.

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ksbsnowowl
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922(r) Compliance on a converted Saiga rifle.

Post by ksbsnowowl » Tue Oct 28, 2014 3:00 pm

I just purchased a new Saiga rifle from Legion USA (they are now sold out, but you can see it here: https://www.legionusa.com/saiga-izsl-mp-7.62-x-39.html )

I probably should have inquired more about the 922(r) parts counts prior to purchase, but I should be able to work with what I've got. After I received the rifle, I sent Legion an e-mail asking for a listing of the compliance parts (note, it was sold to me with a US-made Tapco mag). I got the following response:
This rifle it is only compliant with US made mags. We only used a US made fire control group (3 parts), US made pistol grip (1),and the mag (3 parts). If you want to use foreign mags, you would need to use a US made floor plate and follower in the magazine.
Okay, so I need at least one more US-made part, as I understand it; not a problem, as I was planning to buy and install an Midwest Industries handguard anyway. So, I sent this e-mail reply, just to double-check my parts compliance:
I am planning to buy and attach a US-made hand guard made by Midwest Industries. By my count, that would allow use of foreign-made magazines. Am I correct in this understanding?

After the US-made hand guard, my parts count should be:

Foreign:
(1) Receiver
(2) Barrel
(3) Front Trunion
(4) Bolt
(5) Bolt Carrier
(6) Gas Piston
(7) Butt Stock

US-made:
(1) Trigger
(2) Disconnector
(3) Hammer
(4) Pistol Grip
(5) Hand Guard

This leaves me with 3 unused foreign parts slots, which should allow the use of a completely foreign magazine, bringing my foreign parts count to the allowed 10, correct?
His reply left much to be desired, and so far as I understand the law, he doesn't seem to understand 922(r) correctly:
From my understanding, you need to have at least 6 US parts on a rifle.
To which I replied:
Common misconception. What actually matters is that you have no more than 10 foreign parts (from the 922(r) list) on the rifle. A typical AK-47 has 16 parts that 922(r) cares about (all the ones I listed above, plus a muzzle attachment). That means that yes, typically, an AK-47 needs 6 US-made parts. However, the firearm I purchased from you does not have a muzzle attachment, so it only has 15 parts. Ergo, I should only need 5 US parts to be in compliance, at least as far as I understand the law.

See here:
http://forum.saiga-12.com/index.php?/to ... nd-rifles/
and here:
http://jobson.us/922r/
and here:
http://thegunwiki.com/Gunwiki/BuildSaig ... Compliance
and here:
http://thegunwiki.com/Gunwiki/BuildAkVerifyCompliance
He finally replied:
Our understanding is that if it has a muzzle device than you need 7 parts not 6. That is why I said you needed 6 parts. ...
In searching on the topic today, I found a blog post by Cheaper Than Dirt that seemed to side with my interpretation (so long as you have no more than 10 foreign parts), but also not (stating you had to have 6 US parts), as it spoke under the assumption that all AK-47's would have 16 applicable parts. Mine doesn't have a threaded muzzle, and as such does not have a muzzle device; thus, it only has 15 parts.

Note, I do intend to contact the BATFE before using anything other than a magazine with at least one US part in it, after adding the US hand guard (which would give me 6 parts, until I get clarification).

So, AK-lovers, is my understanding correct, and after replacing the Russian-made hand guard with a US-made one, I'll be good-to-go on using com-block steel mags?
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Mr. E. Monkey
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Re: 922(r) Compliance on a converted Saiga rifle.

Post by Mr. E. Monkey » Tue Oct 28, 2014 11:05 pm

My understanding is that you are correct:
(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.
http://thegunwiki.com/JustTheLaw/RefFedCFR178_39

And, if you're worried about it, or just want some wiggle room, you could get a US made buttstock too.
(Nevermind, just saw that you got the folding stock. Probably don't want to mess with that.)
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Re: 922(r) Compliance on a converted Saiga rifle.

Post by IceWing » Wed Oct 29, 2014 10:02 am

ksbsnowowl wrote:
Note, I do intend to contact the BATFE before using anything other than a magazine with at least one US part in it, after adding the US hand guard (which would give me 6 parts, until I get clarification).
Respectfully, do you REALLY want to contact BATFE and bring a spotlight onto yourself?

That doesn't seem, to me at least, to be a very good idea...
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NamelessStain
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Re: 922(r) Compliance on a converted Saiga rifle.

Post by NamelessStain » Wed Oct 29, 2014 3:53 pm

Switch over your butt stock and you can use the original mags that came with it since you would only have 9 foreign parts.
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ksbsnowowl
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Re: 922(r) Compliance on a converted Saiga rifle.

Post by ksbsnowowl » Wed Oct 29, 2014 5:27 pm

NamelessStain wrote:Switch over your butt stock and you can use the original mags that came with it since you would only have 9 foreign parts.
It's a Russian-made folding stock. I'd rather keep it.
The lion sings and the birds take flight,
The moon by day and the sun by night.
Blind woman, deaf man, jackdaw fool,
Let the Lord of Chaos rule!

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