922(r) complinance ?

[Mity2]

So I have recently converted my Zestava M92PAP pistol in to Form1 approved SBR.
Since M92PAP was imported as pistol, there was no need for it to be 922(r) compliance, and as such, its almost entirely made up with Serbian made parts.
Which is all fine and dandy, until I legally reclassified it to Short Barreled Rifle.
As rifle, its now required to comply with 922(r), correct?

What Serbian made parts do I need to switch with US made parts to comply with 922(r)?
And how many such parts must be present in the said firearm order for me to be complaint with 922(r)?


So far, I have following US made parts installed.

Stormworkz hinged folding buttstock adaptor
Manticore triangle buttstock

On order:
ALG Defense AK Trigger kit
Midwest Industory Yugo M85/M92 Krinkov railed Handguard

Thanks in Advance

[GunLawyer001]

ATF used to say that NFA firearms were exempt from 922(r). Now ATF is not so sure, and any opinion you find may change tomorrow:

https://johnpierceesq.com/does-922r-...ported-pistol/

[marinville]

You have five countable parts. The stormwerks adapter isnt countable. Adding a US made pistol grip or muzzle device will get you there, assuming there is where you want to be. As stated, its debatable whether or not NFA registered firearms must comply with 922r.

[Mity2]

ATF used to say that NFA firearms were exempt form 922(r). Now ATF is not so sure, and any opinion you find may change tomorrow:

https://johnpierceesq.com/does-922r-...ported-pistol/

And your likely dead on with that assumption of ATF's habitual tendencies to change of opinions in some matter from day to day it seem.
But as Mr.Pierce, concluded in the bottom of the post, I think its best to assume that the from statutory interpretation and from the trend in ATF guidance that 922(r) does apply to the making of an SBR from an imported pistol, and that I should make sure that my SBR is 922(r) compliant.

now according to this article https://www.law.cornell.edu/cfr/text/27/478.39#c listed in Cornell University Law school, its basically stating that there should be no more than 10 of the imported parts listed in paragraph (c) of above listed page.

I have US made magazine(Pmag), that covers 18, 19, and 20(mag body, mag follower, and floor plate). 3 parts
The ALG Defense AK Trigger I have in order, which consists trigger, sear, and hammer. So that will cover 11, 12, and 13(Hammer, sear, and trigger).
3 parts

I got Manticore butt stock, and Magpul grip, which would cover 15, and 16.
2 parts


And Midwest forearms that's on order will cover 17.
1 part

So that's 9 US made parts. I need one more.
I'm guessing precure some US manufactured muzzle device(currently equipped with Bulgarian made Krink booster) to replace what is on there currently is most cost effective way?

[marinville]

And your likely dead on with that assumption of ATF's habitual tendencies to change of opinions in some matter from day to day it seem.
But as Mr.Pierce, concluded in the bottom of the post, I think its best to assume that the from statutory interpretation and from the trend in ATF guidance that 922(r) does apply to the making of an SBR from an imported pistol, and that I should make sure that my SBR is 922(r) compliant.


now according to this article https://www.law.cornell.edu/cfr/text/27/478.39#c listed in Cornell University Law school, its basically stating that there should be no more than 10 of the imported parts listed in paragraph (c) of above listed page.

I have US made magazine(Pmag), that covers 18, 19, and 20(mag body, mag follower, and floor plate). 3
The ALG Defense AK Trigger I have in order, which consists trigger, sear, and hammer. So that will cover 11, 12, and 13(Hammer, sear, and trigger). 3
I got Manticore butt stock, and Magpul grip, which would cover 15, and 16. 2
And Midwest forearms that's on order will cover 17. 1

So that's 9 US made parts. I need one more.
I'm guessing precure some US manufactured muzzle device(currently equipped with Bulgarian made Krink booster) to replace what is on there currently is most cost effective way?

There are 16 countable parts in a stamped AK. No more than ten may be foriegn, meaning you need 6 US made countable parts. If you have all the parts you mentioned in this post, you are well over the count... meaning you are compliant as is.

[marinville]

Countable parts on an AKM:

Receiver
Barrel
Barrel mounting trunnion
Bolt
Bolt carrier
Gas piston
Hammer
Trigger
Sear
Stock
Pistol grip
Handguard
Muzzle device
Magazine body
Magazine follower
Magazine baseplate

[GunLawyer001]

And your likely dead on with that assumption of ATF's habitual tendencies to change of opinions in some matter from day to day it seem.
But as Mr.Pierce, concluded in the bottom of the post, I think its best to assume that the from statutory interpretation and from the trend in ATF guidance that 922(r) does apply to the making of an SBR from an imported pistol, and that I should make sure that my SBR is 922(r) compliant.

now according to this article https://www.law.cornell.edu/cfr/text/27/478.39#c listed in Cornell University Law school, its basically stating that there should be no more than 10 of the imported parts listed in paragraph (c) of above listed page.

I have US made magazine(Pmag), that covers 18, 19, and 20(mag body, mag follower, and floor plate). 3 parts
The ALG Defense AK Trigger I have in order, which consists trigger, sear, and hammer. So that will cover 11, 12, and 13(Hammer, sear, and trigger).
3 parts

I got Manticore butt stock, and Magpul grip, which would cover 15, and 16.
2 parts


And Midwest forearms that's on order will cover 17.
1 part

So that's 9 US made parts. I need one more.
I'm guessing precure some US manufactured muzzle device(currently equipped with Bulgarian made Krink booster) to replace what is on there currently is most cost effective way?

I agree that the safest approach is to assume that 922(r) applies.

And you are right to point out that the law applies to imported parts included, rather than domestic parts added. A number of folks over the last few decades make the mistake of flipping the rule, and thinking that you can make a firearm legal by adding US-made scope mounts, flashhiders, flashlights, etc. It's an easy mistake to make; if a gun has 15 parts, there's no difference between saying that it can't have more than 10 imported or that it must have at least 5 domestic parts.

It's also important to remember that some of the "parts" are actually assemblies made up of smaller parts, although ATF deems the assembly to be 1 "part". Other assemblies, like detachable mags, count every sub-part as a "part". (If you like to have a lot of magazines, it's cheaper to replace 3 gun parts so you can use imported mags.)

[Sgt.K]

And non-gunners say "how hard can it be to just follow the law?"

Cripes...

[Berks_Iraq_Vet]

Thought we can opt out of laws now if we do not agree with them.....

[flabbydan]

Thought we can opt out of laws now if we do not agree with them.....

"They" can. "We the People" aren't so special.