922r Compliance

This is straight off TAPCO's Website

The Magic Number 10

This is an attempt to offer a better understanding of the 922r rule and is by no means an attempt to give official legal advice.

Title 18 Chapter 44 Section 922(r) of the United States Code, defined further by Title 27 Part 478.39 of the Code of Federal Regulation (CFR), ambiguously restricts semiautomatic rifles and shotguns to no more 10 imported parts from a list of 20 parts.

This one section containing a few paragraphs creates far too much confusion. This short synopsis is an attempt to clarify, in simple terms, the 922r regulation. Hopefully this can offer a simple way to evaluate your rifle or shotgun in order to easily assess what you need to do to ensure your rifle is compliant.

When considering compliance the big thing to keep in mind is the magic number 10! The infinite wisdom of the federal government has decided that it is unlawful for your semi-auto rifle or shotgun to have more than 10 imported parts from their select list of 20 parts. Many describe this in terms of U.S. parts count, but in reality this should be the foreign parts count. Now this is where the debate occurs.

27 C.F.R. 478.89 lists 20 parts:

(1) Frames, receivers, receiver castings, forgings or stampings

(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) Butt stocks

(16) Pistol grips

(17) Forearms, hand guards

(18) Magazine bodies

(19) Followers

(20) Floorplates

Of these twenty parts, the laws states that you can have NO MORE THAN 10 imported parts on your semi-automatic rifle or shotgun. These twenty parts are meant to cover all platforms, and as you know all platforms are not the same. Without getting into specific platforms, starting out you know that you will not have to change more than 10 parts to ensure your rifle is compliant.

There are arguments like “the SKS does not have a pistol grip so that is not a compliance part for the SKS”. If your SKS has no pistol grip and you choose not to add one, then this is correct. BUT, if you buy an aftermarket stock that contains a pistol grip, you have just added a part that is in the parts list and it will count against you if it is not U.S. made. It does not matter if the platform does not have a covered part normally, it matters what you have on your rifle or shotgun.

A suggestion to ensure compliance and to understand how 922r applies to you is to:

(1) Find out all of the possible parts that apply to YOUR rifle. Below you will find a list of the parts applicable to the FAL, AK, SKS and SAIGA.

(2) Lay your rifle down and start counting. (Unloaded and safe of course)

(3) Go down the list of parts that are applicable to your rifle and find each part on your rifle. Make a check for each item you have that is a foreign part.

(4) When you get to the end, add up all the parts that you have that are foreign. If your foreign parts count adds up to ten or less then you are compliant. If not, you need to start replacing some of those foreign parts until you get down to ten or less foreign parts.

Note: TheGunWiki.com is useful for this, but be aware that the parts count used on that site consider what is standard on the weapon as applicable parts and does not consider certain extra parts, such as a pistol grip. For instance, the SKS list of parts has the Pistol Grip as N/A, but as previously mentioned, if you are adding a pistol grip it will count. Still this is a very helpful tool; just remember to look at ALL the parts to make sure you are not adding something that falls under 922r.

Now it is not always this easy, given the way the BATF may categorize parts. For instance, what is commonly seen as the Operating Rod on the SKS is seen by the BATF as a “piston extension” and does not fall under 992r. Then for some platforms like the Saiga shotguns, what looks like the piston is not. Saiga manuals define their piston for the shotgun versions as the small “puck” in front of the “bolt carrier extension” (which could easily be confused for the piston itself).

Best practice is when in doubt, ASK. Either check with the BATF or with the manufacturer of the part.

Another concern out there is the 3 compliance parts in a U.S. made magazine and if “my rifle is not compliant when I take my mag out”. Once again, think about the nature of the law. It is not the number of U.S. made parts you have; it is the number of foreign parts you have. If you have a U.S. made magazine in your weapon and your weapon is compliant with it in, by removing your magazine you are not ADDING more foreign made parts, so you continue to be compliant. Unless you put a foreign made magazine in, thus adding foreign made parts, you are not making your weapon noncompliant. The same thing applies when you are looking at a part that your weapon may not be equipped with. For instance, an SKS without a pistol grip or threaded barrel, the lack of a muzzle attachment or pistol grip, in essence, yields that part not foreign. Just ensure that if you add either item that you recount your parts again or simply make sure the item you are adding is a U.S. made part. Below is the wording from 18 U.S.C. § 922(r) and 27 CFR 478.39

Disclaimer: This is an attempt to present this law. Information taken from this context should not be considered permission to manufacture semiautomatic rifles.

18 U.S.C. § 922(r)

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 section 925(d)(3) of this chapter as not being particularly suitable for or readily adaptable to sporting purposes except that this subsection shall not apply to -

(1) the assembly of any 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 any such rifle or shotgun for the purposes of testing or experimentation authorized by the Attorney General.

27 CFR 478.39 - ASSEMBLY OF NON-SPORTING SHOTGUNS AND SEMIAUTOMATIC RIFLES FROM IMPORTED PARTS

(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 Sec. 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 are:

(1) Frames, receivers, receiver castings, forgings or stampings

(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) Butt stocks

(16) Pistol grips

(17) Forearms, hand guards

(18) Magazine bodies

(19) Followers

(20) Floor plates

EFFECT ON STATE LAW

Expiration of the Federal law will not change any provisions of State law or local ordinances. Questions concerning State assault weapons restrictions should be referred to State and local authorities.

U.S. Department of Justice
Bureau of Alcohol, Tobacco,
Firearms and Explosives

As mentioned above, the below chart shows which regulated parts are contained in each rifle.

Just how many of these parts are in an SKS Carbine?

Here are the relevant parts in an SKS Carbine:


1. Receiver

2. Barrel

3. Bolt

4. Bolt carrier

5. Gas piston
US Made Tapco Part is available)
6. Trigger housing

7. Trigger

8. Hammer

9. Sear

10. Disconnector

11. Stock
(Replace w/ Tapco US Made Part)
12. Handguard
(Replace w/ Tapco US Made Part)
13. Magazine body
(Replace w/ Tapco US Made Part)
14. Magazine Follower
(Replace w/ Tapco US Made Part)
15. Muzzle attachment (YUGO) (Remove it, OR Replace it w/ Tapco US Made Part OR do like we did in our lasest DVD,,, and put a M16 Flash Hider on it!

Note: This list has been confirmed by ATF.

For Standard SKS Carbines (NON Yugo)...If you replace the 4 parts you're down to Ten... and thus "legal".... And You Yugo SKS owners will need to either REMOVE the foreign Muzzle Device... or Replace it with a US Made Part.... Which is what we did in "Modding Your SKS Volume 2 - The Front End" OR... you could swap out the Gas Piston... and THAT would get you down to "Not more than TEN Foreign Parts"...