View Full Version : BENELLI M 1 SUPER 90 922R Parts Count?

06-16-2011, 6:18 PM
I coudn't find an actual parts list ofr what BATF considers the parts for this shotgun\
My brother says his is compliant because he has US made stocks a follower charging handel and magazine extendsion/ But all I keep finidng are the number of parts for the M4?

Anyway, using that couynt/ he is good but I dont know if the M1 has more parts than the M4?

06-17-2011, 9:12 AM
I mgoing down the lost myself/
Does the Benilli have a Trunion?

06-17-2011, 1:27 PM
lol. If you have an HK branded(preban) benelli you are fine and don't have to worry about 922. If you don't, you will need 3 parts is my understanding. The easiest way to do it is get a follower, mag extension and a surefire forend. Unfortunately on the benelli, the charging handle doesn't count on the parts count list according to the ATF. Please know that I am not a lawyer nor work for the ATF but my findings and the collective understanding of the forums I have read say you need 3 us parts. Charging handle not being one of them.

06-17-2011, 1:51 PM
Mesa and Speedfeed also makes a stock for the M1 I believe... I am just not a huge fan of the pistol grips on benelli's

06-17-2011, 3:27 PM
Aah/ thanks guys
He has this american made dessert colored stock and hanguard set that is a straight stock withno pistol gripon it now. So he has over the amount of cpomliance parts by 1.

And No its not a HK made beneli.

06-19-2011, 9:35 PM
Here is part of an ATF letter stating the M4 has only 11 imported parts. The M4 also has a gas piston so (to be safe), people are replacing as many parts as they can find. As ATF will mail out all kinds of opinions.
Here they say the M1 (less parts than the M4) has 13 parts... they sound as reliable as our DOJ tech branch. For the record, Benelli calls their bolt a bolt and bolt head (so, the first letter makes more sense) AND both opinions count the PG and stock while the 2nd letter writer opines the two would count as 1 part depending on the specific model of stock.

06-20-2011, 3:54 PM
The ATF opinions are all over the place.

However what baffles me is the M4 letter doesn't count the piston(s) the M4 has...below is the list of countable parts, I'll put an (M1) (M4) and (M1014)* next to the parts to indicate what has what to the best of my knowledge.

(1) Frames, receivers, receiver castings, forgings or stampings (M1) (M4) (M1014)
(2) Barrels (M1) (M4) (M1014)
(3) Barrel extensions
(4) Mounting blocks (trunions)
(5) Muzzle attachments
(6) Bolts (M1) (M4) (M1014)
(7) Bolt carriers (M1) (M4) (M1014)
(8) Operating rods
(9) Gas pistons (M4) (M1014)
(10) Trigger housings (M1) (M4) (M1014)
(11) Triggers (M1) (M4) (M1014)
(12) Hammers (M1) (M4) (M1014)
(13) Sears
(14) Disconnectors (M1) (M4) (M1014)
(15) Buttstocks (M1) (M4) (M1014)
(16) Pistol grips (M1014)
(17) Forearms, handguards (M1) (M4) (M1014)
(18) Magazine bodies (M1) (M4) (M1014)
(19) Followers (M1) (M4) (M1014)
(20) Floorplates

*Note: when I say M1014 I am assuming the M1014 has the collapsible albeit pinned stock which is two parts (stock proper and pistol grip), and when I say M4 I am assuming it has the fixed PG stock which to the best of my knowledge is one part (it is most certainly one piece, how you can get two parts from one defies all logic so I would assume it would be considered a buttstock, not a buttstock and a pistol grip)...this is important.

Count 'em up. M1014 would be 14, M4 13, and M1 12.

Thus by any reasonable standard I would argue that replacing the magazine body and follower on the M1 would be enough as that puts you at 10. The ATF letter obviously disagrees with me.

It does seem ATF is notoriously bad about these things, being as for the M1 they summoned a pistol grip from the ether (remember, this is counting parts, not features), and on the M4 they ignored the disconnecter, the piston(s), and the bolt carrier. Don't know what kind of screwed up M4 that agent was looking at when he made that assessment, but it's like no M4 I've handled. :rolleyes:

Now, obviously I am not a lawyer and my post should not be construed as legal advice.

06-20-2011, 4:19 PM
Yeah, I saw that 12 parts too. Though my chances are slim to none to get charged with a 922 violation, I rather side with caution. Better to buy a stupid part than go to court... even to show two atf documents that contradict their own findings of 12 vs 13 parts.

06-20-2011, 10:43 PM
I have to admit their stance on a "bolt carrier" bugs as well...
Nowhere in the Benelli parts lists is there such a thing. They only sell complete bolts.
But its ATFs rules.
So, better safe than sorry. My M3 has an op rod but no gas piston, so Im treating it as 13 parts as well.

That David guy is LUCKY! 11 part M4... I'd frame that letter in gold.

Here's what I came up with (thanks to pebcak for the m4 1014 info)

06-21-2011, 7:02 AM
I want to make a parts coumt list for that and give it to my brother/ Like how safer Cgn members get a flow chart copy/ or should he get his own ATF letter?

06-21-2011, 7:49 AM
I want to make a parts coumt list for that and give it to my brother/ Like how safer Cgn members get a flow chart copy/ or should he get his own ATF letter?
If he's at all worried he should get a letter. In court, logic might stand up, but a letter with his name on it from the ATF with a parts count is likely to keep him out of court in the first place so long as he follows the guidelines within.

06-21-2011, 8:16 AM
Sorry to sound so confused, but I guess that is the purpose of 922r in any case. Is someone modifying their shotgun to a "non sporting" configuration, and thus subject to the 922r headache, or does this apply to any of these shotguns, even bone stock as purchased?

06-21-2011, 7:13 PM
It's for people looking to re-configure a "BATF approved" import. My M3 has a straight stock with a 5 round magazine it was brought into the states legally, by being sporterized.

So by changing 3 "922r named" parts to US made parts, I can have a pistol gripped stock and a 7 round magazine. As now my Benelli M3 will be made of 10 or less imported parts.