question on standard cap mags

[m60gunner29]

I have been reading quite a bit lately on the forums and I see references to two things I am looking for clarification on. I have read the DOJ PDF letter of 10 NOV 2005 that references magazines but I still have questions.

First, I see people referring to disassembling standard cap mags before bringing them across the border into California. The group consensus seems to be if the magazine is disassembles it no longer fits the definition of a high cap mag. This despite the probability that all the parts are being stored in the same zip lock baggie and in immediate proximity of each other. Is there a DOJ letter on this or is this simply an adopted opinion from group discussions?

Second, I hear people referring to magazine rebuild kits being legal to buy from out of state vendors. Are these typically missing some part so the baggie of parts couldnt be assembled into a functioning magazine or do these have ALL the parts to make a magazine and simply disassembled? Once again wondering if there is a DOJ letter on this or if has evolved from legal logic discussions here.

Im trying to make sence of this whole magazine issue. Appreciate any help.

[JeffM]

For most purposes regarding getting a position from them, the DOJ is fairly worthless. The best most of us can do is to read and understand the law for ourselves. However, there is lots of info here on Calguns to help accomplish that.

The way the law is written, there is no "constructive possession" for large capacity magazines, so even in the same baggie/box, all the parts needed to construct a magazine are just that: parts, not a magazine. When a vendor refers to a "parts kit", unless otherwise stated, it usually means the complete set of parts needed for a functioning magazine.

[m60gunner29]

The way the law is written, there is no "constructive possession" for large capacity magazines, so even in the same baggie/box, all the parts needed to construct a magazine are just that: parts, not a magazine. When a vendor refers to a "parts kit", unless otherwise stated, it usually means the complete set of parts needed for a functioning magazine.

Well that sounds great. But...
If I had a 30 round ar15 magazine, and I took it apart so it was all in pieces, it could really be "a collection of repair parts" or "a magazine disassembled for cleaning" so really, its sort of an interpretive opinion it would seem.

I've been reading a LOT of posts here lately but I havent come across a DOJ position letter stating that a disassembled mag was or wasnt (in DOJ opinion) a high cap mag.

To be more specific, If I decided to take that same disassembled baggie of parts (complete disassembled magazine) to a gun show and sell it, what response could I give to a cop that makes the claim 'thats a high cap mag just disassembled, and a violation because you are displaying it for sale'. Im wondering how I would render word-fu to get out of trouble.

Im just trying to get a better understanding of it all, the whole 'replacement parts set vs disassembled magazine'.

[JeffM]

Good luck then. There are many lengthy threads on the subject.

[Sam]

Well that sounds great. But...
If I had a 30 round ar15 magazine, and I took it apart so it was all in pieces, it could really be "a collection of repair parts" or "a magazine disassembled for cleaning" so really, its sort of an interpretive opinion it would seem.

I've been reading a LOT of posts here lately but I havent come across a DOJ position letter stating that a disassembled mag was or wasnt (in DOJ opinion) a high cap mag.

To be more specific, If I decided to take that same disassembled baggie of parts (complete disassembled magazine) to a gun show and sell it, what response could I give to a cop that makes the claim 'thats a high cap mag just disassembled, and a violation because you are displaying it for sale'. Im wondering how I would render word-fu to get out of trouble.

Im just trying to get a better understanding of it all, the whole 'replacement parts set vs disassembled magazine'.

What about selling the parts in different baggies as different items rather than as a kit? "You can buy my mag body for 10 bucks, but I also have the spring and follower for sell right here for a cent a piece." I don't think it's really an issue though, I've never heard nor read about a similar case.

[domokun]

To be more specific, If I decided to take that same disassembled baggie of parts (complete disassembled magazine) to a gun show and sell it, what response could I give to a cop that makes the claim 'thats a high cap mag just disassembled, and a violation because you are displaying it for sale'. Im wondering how I would render word-fu to get out of trouble.


A sponsoring vendor of Calguns has already sold magazine rebuild kits at the last Cow Palace gun show. No problems with any of the police officers or incognito DOJ BOF agents that were roaming around the show. If they were to bust someone for what you're worried about, they would have done so at the show already.

[bohoki]

nobody can tell me how many a standard capacity magazine holds

[CSACANNONEER]

nobody can tell me how many a standard capacity magazine holds

Two. But, I roll big joints. Ooops, wrong forum. I guess the same concept sort of applies though.

[MudCamper]

m60gunner, it sounds like what you want is a definitive answer from the DOJ. That is something that does not exist. That is not something you will ever get. They don't want us to even own guns, but they can't come right out and say that because we legally can, so they spread FUD. The opinion letter (http://www.hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf) you have already seen is as good as it gets. They don't even issue those anymore.

[bill104]

In My Opinion, if youre selling at any type of open Market, it would depend on how you label the the Magazine, if you toss all the parts in a bag and write on it (30 rd Mag) you would be trying to sell just that, which is why you would see something more like, (repair kit for 30 rd mag) implying youre selling all parts needed to fix one you own that needs parts. sort of like me, My father passed away 2 years ago, and I keep finding all these old wore out Mags that need repairing, which is why I keep buying repair kits, in 20 and 30 rd configurations. Dang look here I just found 4 more old P-mags with cracked housings, I guess I have to buy 4 more complete repair kits.

[B Strong]

I have been reading quite a bit lately on the forums and I see references to two things I am looking for clarification on. I have read the DOJ PDF letter of 10 NOV 2005 that references magazines but I still have questions.

First, I see people referring to disassembling standard cap mags before bringing them across the border into California. The group consensus seems to be if the magazine is disassembles it no longer fits the definition of a high cap mag. This despite the probability that all the parts are being stored in the same zip lock baggie and in immediate proximity of each other. Is there a DOJ letter on this or is this simply an adopted opinion from group discussions?

Second, I hear people referring to magazine rebuild kits being legal to buy from out of state vendors. Are these typically missing some part so the baggie of parts couldnt be assembled into a functioning magazine or do these have ALL the parts to make a magazine and simply disassembled? Once again wondering if there is a DOJ letter on this or if has evolved from legal logic discussions here.

Im trying to make sence of this whole magazine issue. Appreciate any help.

No Such Letter exists.

The whole situation can be summed up with an old saying, Parts is Parts

You can legally replace every single part on a lawfully owned high capacity magazine, and that's all you really need to know.

In reading the California Penal Code section 12020 wrt high capacity magazines, there is not one word included that forbides or qualifies the repair of lawfully owned high capacity magazines.

[Quiet]

I have read the DOJ PDF letter of 10 NOV 2005 that references magazines but I still have questions.
No Such Letter exists.
Is it this CA DOJ letter (http://hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf)?

[m60gunner29]

Is it this CA DOJ letter (http://hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf)?

yes thats the letter I had seen

man reading and reading and reading HOURS OF READING ....

the one post made it to 59 pages :O

I'm really considering going into the mag business in cali.

I'm on the fence about starting a armored car business or selling full cap mags disassembled and minus the spring or some other piece (because I just cant wrap my head around why its not a magazine if its disassembled.)

I just think the average street cop at a gun show wont be able to understand the concept of disassembled isnt a mag.... just like I cant. It would be easy to sell the 'i got an armored car business' as its black and white. (And yes I have a way to legitimise an armored car business).

I mean I am looking at this from a potential business and not to do it to 'stick it to the man' type exercise.

[bdsmchs]

(because I just cant wrap my head around why its not a magazine if its disassembled.)


If it's disassembled then it cannot feed ammunition into a firearm.

It's exactly the same as separating an AR upper from a lower. At that point you can slap a standard magazine release button/catch in the lower because it is no longer a "Semi-automatic, centerfire rifle".

Why can't you wrap your head around that?

To be a magazine it must function as a magazine. A bag of parts cannot function as a magazine and therefore it IS NOT a magazine.

[m60gunner29]

Dont get me wrong - i want to believe.

But like your example with the rifle that has been push pin seperated, if both parts were found in the same rifle carry bag, anyone would consider that a rifle and not a collection of parts.

I havent seen any 'meat' to the argument about disassembled.

I HAVE read lots of meat about armored car companies, FFL's being seller exempt, theres no crime anywhere about BUYING, etc...

but the disassembled idea - I just dont know where this concept started and nobody seems to be able to cite anything anywhere to base this logic on, everyone seems to just want to fight me, which is odd because as I say i'd LIKE to buy this idea - it just doesnt make sence

[JeffM]

We're not talking about the NFA that calls machine gun parts a machine gun, or the GCA that calls a stripped receiver a "firearm".

PC 12020 makes no such provision. It is about large capacity ammunition feeding devices, making no reference or inference to their parts. If the parts aren't together, then it can't be a "feeding device". A spring is a spring, a follower is a follower, a body is a body, etc, etc.

But it sounds like you shouldn't be in business of any kind if you have trouble understanding that.

[ENTHUSIAST]

We're not talking about the NFA that calls machine gun parts a machine gun, or the GCA that calls a stripped receiver a "firearm".

PC 12020 makes no such provision. It is about large capacity ammunition feeding devices, making no reference or inference to their parts. If the parts aren't together, then it can't be a "feeding device". A spring is a spring, a follower is a follower, a body is a body, etc, etc.

But it sounds like you shouldn't be in business of any kind if you have trouble understanding that.

Well said. :iagree:

This is a really basic concept here... stop being so paranoid geez!

[ohsmily]

No Such Letter exists.

The whole situation can be summed up with an old saying, Parts is Parts

You can legally replace every single part on a lawfully owned high capacity magazine, and that's all you really need to know.

In reading the California Penal Code section 12020 wrt high capacity magazines, there is not one word included that forbides or qualifies the repair of lawfully owned high capacity magazines.

Gee, that's funny, if there is no letter, then what the heck is this http://hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf (it addresses all of your questions pretty clearly).

[m60gunner29]

But it sounds like you shouldn't be in business of any kind if you have trouble understanding that.

Your moderately insulting post only serves to confirm my suspicions. Somehow some people on this board through what I can only describe as group psycosis have convinced each other this 'disassembly theory' is viable when clearly, no judge, no attorney and no street cop would buy such an argument. Thats fine with me. By all means accept the validity of the disassembly theory if that makes you happy.

As to my background, my first FFL was issued to me in Ranch Cordova (California) late 1994 and I have had two other FFL's issued to me in Las Vegas since then. The whole time I have been in the gun business I have been building assault rifles and working on registered legal NFA devices. I have traveled extensively through multiple jurisdictions selling legally at (I cant cont how many) gun shows in most every western state.

And you think you are going to tell me about running a gun related business?.

Let me tell YOU something. You dont go into a firearms related business without having the i's dotted and the t's crossed. You do not make snap decisions. You do not do things that you cant back up with fact and law. You do not do things 'cause the internet said it was ok'. Break those rules and you will end up with free shiney bracelets and free room and board. I know literally dozens of people over that time period that ended up dead, arrested, witness protection or fled the country. In the gun business you have two choices - follow the law or get in trouble. Personally I have learned that follow the law is better.

As I stated before i'd like to buy this disassembly theory but just saying something is so doesnt make it so. Getting hostile and argumentative doesnt make it so.

People on this board seem to like to read. Instead of selectively reading the part of the DOJ letter go back and read the whole thing. The author specifically says by disassembling a magazine and bringing it across the state line or by having enough replacement parts to make a new one, in either of those two instances you could be charged with a felony.

Now, I dunno how many people you personally know that have been charged with federal felonies, I know several. It didnt look fun from where I was standing any of those times. I can tell you I dont want that for me.

If you had all the parts to make a mag MINUS ONE, in that case I can see you referring to it as a repair parts set and since it couldnt function assembled or not as a magazine, well thats what it would be.

But even after being somewhat attacked and insulted (neither of which I think was called for), I still see no logic or legal argument to support the 'disassembly theory'. So this is what ill do, I'll stop posting on this topic. Apparently this topic will only degrade into name calling, insults and hostility.

[wash]

The problem is the transactions you are talking about are already happening in the open.

As an FFL you should know that parts is parts.

It's not illegal to buy or own any of the parts that make up a standard capacity magazine separately and it's not illegal to buy or own any of the parts that make up a standard capacity magazine together.

It's manufacturing and importing that are illegal.

It's just like selling a 14.5" AR upper to someone (without a muzzle device). If they don't have an AR pistol or a SBR tax stamp but they do have an AR rifle lower, they committed a crime. Not the seller, the buyer. You can't help it if someone does something stupid with a product you sold them but how would you know?

I know you are nervous but in California it doesn't get any better than "everyone's doing it and no one gets arrested because there is no specific law against it".

[Cypren]

The author specifically says by disassembling a magazine and bringing it across the state line or by having enough replacement parts to make a new one, in either of those two instances you could be charged with a felony.

What the memo author says is that importation of magazine parts (including all of the parts required to construct a magazine) is legal, but importing them all together would test the limits of the law and that you would be at serious risk for prosecution if the DA believed you were manufacturing a new magazine.

The safest way of handling this is to disassemble the magazines, group the parts by type (rather than by magazine) and import them in separate shipments. Possession is not illegal and therefore once you have taken delivery of the parts, you cannot reasonably be charged with anything unless you manufacture a new magazine and the DA can prove it. Grouping them by replacement part type rather than by magazine substantially reduces the chance that he can convince a jury you were importing a new magazine. Of course, if you don't already have magazines of the same type, and you aren't in the arms business, the DA will probably feel a lot more bold.

The memo does provide legal cover, but you are right that the people who say, "disassemble the magazine, put all the parts in a bag and ship it" are probably seriously understating the risk of prosecution if the shipment is intercepted.

[CSACANNONEER]

But even after being somewhat attacked and insulted (neither of which I think was called for), I still see no logic or legal argument to support the 'disassembly theory'. So this is what ill do, I'll stop posting on this topic. Apparently this topic will only degrade into name calling, insults and hostility.

So, please explain why you feel that constructive possession would some how apply to magazine parts in California law. It clearly doesn't! If it was illegal to sell complete kits, there would be a lot of busts at gun shows where they are openly offered for sale. Having an FFL or working on NFA items doesn't mean that you know the laws. Believe me, there are many FFLs in Ca who have been in business a lot longer than you and they still believe that OLLs are illegal here. I'm not trying to call you names or imply that you don't know how to run your business. I'm just asking for you to clarify your thoughts and letting you know that both the name calling from others and your chest pounding are irrelevant when it comes to this civilized discussion.

[m60gunner29]

So, please explain why you feel that constructive possession would some how apply to magazine parts in California law.

this is the problem in its most basic example....

If you owned a high cap magazine in california and you take it apart to clean it and then reassemble it, will you have manufactured a new magazine?

If reassembling a magazine after you took it apart to clean isnt considered manufacturing a new magazine because it was always a magazine throughout the whole process, then the baggie of parts consisting of a complete disassembled magazine would ALSO (still) be a magazine.

In both cases assembled or disassembled would be irrelivant.

The only way these baggies of disassembled parts could be a 'rebuild or replacement parts set' is if it were missing a part so it couldnt function as a magazine.

[B Strong]

Gee, that's funny, if there is no letter, then what the heck is this http://hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf (it addresses all of your questions pretty clearly).

Sorry ohsmily - I should have made it clear that I was refering to the OP's request for a letter specifically authorizing the sale of complete magazine repair parts kits.

[Quiet]

this is the problem in its most basic example....

If you owned a high cap magazine in california and you take it apart to clean it and then reassemble it, will you have manufactured a new magazine?

No. Because you are performing maintenance on your legally owned large capacity magazine, not manufacturing a new large capacity magazine.

Maintenance, repair, and modification of a large capacity magazine is not prohibited in 12020(a)(2).

Penal Code 12020
(a) Any person in this state who does any of the following is punishable by imprisonment in a county jail not exceeding one year or in the state prison:
(2) Commencing January 1, 2000, manufactures or causes to be manufactured, imports into the state, keeps for sale, or offers or exposes for sale, or who gives, or lends, any large-capacity magazine.
(b) Subdivision (a) does not apply to any of the following:
(24) The lending or giving of any large-capacity magazine to a person licensed pursuant to Section 12071, or to a gunsmith, for the purposes of maintenance, repair, or modification of that large-capacity magazine.
(25) The return to its owner of any large-capacity magazine by a person specified in paragraph (24).

[Josh3239]

Gee, that's funny, if there is no letter, then what the heck is this http://hoffmang.com/firearms/DOJ-large-cap-magazines-2005-11-10.pdf (it addresses all of your questions pretty clearly).

In addition to this letter, the CA DOJ defines a "high capacity magazine" as an ammunition feeding device. Seeing as how a spring, body, follower, and baseplate in a bag disassembled aren't capable of feeding ammunition they cannot be considered a magazine. And as CSAC pointed out, there is no constructive possession law or any other law that states that parts are the same as a complete and assembled magazine.

If you feel as though we are tip toeing through this "grey area" then don't do it. But the law is pretty clear to the rest of us.

[m60gunner29]

[U]
Maintenance, repair, and modification of a large capacity magazine is not prohibited in 12020(a)(2).

Exactly my point.

By taking it apart to maintain the magazine, it was not turned into a pile of parts but rather a 'disassembled magazine' and was still a high capacity magazine throughout its entire maintainance procedure.

Therefore by taking a magazine and disassembling it and putting it all in the same plastic baggie, it is also still a high capacity magazine and not just a collection of parts.

[m60gunner29]

If you feel as though we are tip toeing through this "grey area" then don't do it. But the law is pretty clear to the rest of us.


It seems to me that so many legal hurdles have been discussed enough to find a loophole or way around them that some here for some reason believe this one has too.

And I'd love that to be the case. But...

Its clear that a lot of people think that if you take a high cap mag apart and put all the parts in the same baggie that its no longer a magazine.

From what I have read and am seeing in this post as well as others, this simply has no basis in the law or fact or logic and discussing it only seems to make people mad.

And I also think perpetuating this myth will eventually end up costing someone on this forum a lot of grief.

[Quiet]

Therefore by taking a magazine and disassembling it and putting it all in the same plastic baggie, it is also still a high capacity magazine and not just a collection of parts.

The status of the item when being imported into CA defines what that item is.

Large capacity magazines are defined by CA law. [PC 12020(c)(25)]

Large capacity magazine parts does not meet the legal definition of a large capacity magazine.

A bag full of magazine parts do not meet the legal definition of a large capacity magazine when they are imported into CA.
Therefore, it is not a large capacity magazine, it is just magazine parts.

While in CA, assembling the magazine parts into a large capacity magazine is illegal, because it is manufacturing a large capacity magazine in CA after 01-01-2000.
Assembling the magazine parts into a permanent 10 round magazine is legal, because it is not manufacturing a large capacity magazine in CA after 01-01-2000.


Penal Code 12020
(c)(25) As used in this section, "large-capacity magazine" means any ammunition feeding device with the capacity to accept more than 10 rounds, but shall not be construed to include any of the following:
(A) A feeding device that has been permanently altered so that it cannot accommodate more than 10 rounds.
(B) A .22 caliber tube ammunition feeding device.
(C) A tubular magazine that is contained in a lever-action firearm.

[Jpach]

M60, what you dont understand is that a bunch of magazine parts DO NOT = a magazine. Who are you to say that a rebuild kit MUST have missing parts? Why would you rebuild/replace a magazine without all necessary parts? Your logic is severely flawed. The reason why disassembling and reassembling your own legal pre-2000 is not considered manufacturing is because YOU HAD THEM AS FUNCTIONING MAGAZINES ALREADY. That is the issue. With your logic it is illegal to even order and receive new magazine parts kits because you are "importing a magazine." In reality, it is not illegal to import all of the parts together not is it illegal to have all new parts together at once. IIRC the DOJ has even proved you wrong in response to Gene Hoffman's/Hoffmang's questions to them. Just what orifice did you pull this out of?

[m60gunner29]

Just what orifice did you pull this out of?
Are you are incapable of a civil discussion or simply unable to provide a rebuttal and feel frustrated?



it is not illegal to import all of the parts together nor is it illegal to have all new parts together at once.

I'm not sure if you simply failed to read the previous 2 pages of posts or could not comprehend the text writen in plain english but yes, this is what I have been saying the entire string. And as of yet nobody has been able to disprove the statement.




IIRC the DOJ has even proved you wrong in response to Gene Hoffman's/Hoffmang's questions to them.

In fact you do remember incorrectly. Or maybe you failed to read the text of the letter for yourself. In either case you will find if you go back and read the text, the DOJ letter says and I quote "In either case you would test the limits of the law and be at risk of criminal prosecution".

So to be clear, NO, the Hoffman letter does NOT say this is legal.

[Meplat]

OK, lets say you have an AR mag that has a weak spring and will not feed the last few rounds. You order a repair kit that contains all components. You replace the spring and follower in the old mag. Now you have a properly functioning mag plus and a pile of parts with an original follower and a weak spring. based on the original follower that is a pre owned mag. You order another parts kit and assembled with the pre owned follower and all other parts new from the kit. You can see how this is kind of like breading rabbits. Is it legale or is it a stretch?

[Dr Rockso]

OK, lets say you have an AR mag that has a weak spring and will not feed the last few rounds. You order a repair kit that contains all components. You replace the spring and follower in the old mag. Now you have a properly functioning mag plus and a pile of parts with an original follower and a weak spring. based on the original follower that is a pre owned mag. You order another parts kit and assembled with the pre owned follower and all other parts new from the kit. You can see how this is kind of like breading rabbits. Is it legale or is it a stretch?

Sounds like you'd be ending up with more standard-cap mags than you started with. Not good.

[Dr Rockso]

M60gunner, I don't think you're going to get a response that will satisfy you on this topic because it seems that you want some sort of 'official' stance on the part of the CA DOJ that parts kits are legal. Unfortunately that isn't what they do. The author of that memo, Alison, would likely say something similar about OLLs; that you're risking criminal prosecution by owning one. Nobody is prosecuted, however, because the attorneys on our side have a well-formed position on the matter that the DAs don't want to challenge. Plain and simply constructive possession has never been established for firearm laws on the state level in California, which makes this particular position (in regards to magazine parts) very defensible.

[m60gunner29]

M60gunner, I don't think you're going to get a response that will satisfy you on this topic because it seems that you want some sort of 'official' stance on the part of the CA DOJ that parts kits are legal. Unfortunately that isn't what they do. The author of that memo, Alison, would likely say something similar about OLLs; that you're risking criminal prosecution by owning one. Nobody is prosecuted, however, because the attorneys on our side have a well-formed position on the matter that the DAs don't want to challenge. Plain and simply constructive possession has never been established for firearm laws on the state level in California, which makes this particular position (in regards to magazine parts) very defensible.


well written and on topic......

hmmmmmmm


(critical thinking in progress)

[JeffM]

Exactly my point.

By taking it apart to maintain the magazine, it was not turned into a pile of parts but rather a 'disassembled magazine' and was still a high capacity magazine throughout its entire maintainance procedure.

Therefore by taking a magazine and disassembling it and putting it all in the same plastic baggie, it is also still a high capacity magazine and not just a collection of parts.

Ok, this line of reasoning makes a lot of sense, but I think your thought process is colored by previous dealings with the BATFE.

Logical or not, it seems that the BATFE has taken a firm stance on many issues, especially regarding NFA items.

For example: once a shoulder stock has been added to a firearm receiver, it can never have a barrel added with a length of less than 16" - once a rifle always a rifle. Unless of course it's a reg'd SBR or MG.

But we are not dealing with the BATFE. We are dealing with the CA DOJ. The DOJ seems to have made it their policy to NOT give hard/fast rulings on issues like the one you describe. And in some instances that is a good thing.

Although you may have some logic in your statement above, as stated more than once in this thread, the "once a magazine, always a magazine" argument has no actual legal standing. It would have to go to court to develop case law to gain that kind of status.

We must however take a few things into account:

1. Many of the recent CA gun laws are poorly written. Many of the laws are also illogical. Trying to apply logic to some of these laws will get you nowhere.

2. Like most CA regulatory agencies, the DOJ is very politically oriented. They, and the BOF specifically, have been hit hard by the AW/OLL debacle, and must tread lightly in order to retain whatever credibility they have left.

3. CA DA offices likewise are political in nature. For the most part, they must take cases that they can win. Being a martyr for the cause has not worked out well for those that have tried obviously losing cases, and lost cases of any significant magnitude are often cause for embarrassment.

4. The "parts kit" market has been wide open for some time now. There have been thousands of transactions involving magazine parts over the last few years.

So while your reasoning may have some logic to it, the law doesn't have anything to say. So considering 1, 2, 3, and 4 above, and in addition to the magazine parts letter, the likelihood of a successful prosecution of 12020 for importing a magazine parts kit is HIGHLY unlikely.

All that said, CA is one of the most gun unfriendly states, and any aspects of gun ownership here caries risk. Many of the people here accept the risk as a mater of fact. It is the cost of doing business, so to speak, as a gun owner in CA. The state of affairs here might color many of our opinions, and there might be an overall desensitization to the risks involved in any venture, but considering all the other risks we take to be gun owners, magazine parts is not high on the list.

If that makes you uncomfortable, then so be it. Sell magazine parts minus one, or sell none. I don't really care. There are plenty of others that have, and will continue to do so, with relative impunity. Its not a fight that the other side could win, and would be a waste resources for them to pursue.