922r and end users

[DrewN]

I see a whole bunch of folks worried about 922r compliance and I'm wondering if anyone has any FIRST HAND knowledge of an end user that got railed for non compliance. In 35 years of shooting at various ranges I've never seen anyone enforce anything, except maybe a token appearance or two after a major change in the law. I doubt there's 5 LEO's of any agency in the entire state who could take your gun apart and name all the parts, much less what brand they are and where they are made. I can see if you are manufacturing for sale, obviously.

[-hanko]

BATFE came out with an opinion letter...

...quite a while ago.

The opinion noted that section 922(r) was intended for IMPORTERS, NOT for non-importers who build rifles.

There has never been an individual builder cited under 922(r).

That said, 922(r) violation(s) caused havoc with Inter Ordnance...enough that they changed their name to Royal Tiger.

[bohoki]

ah the good old 10 parts rule yea i have never heard of any individual being charged but i was extra careful when i upgraded my mak90 back in the 90s
anyone remember replacing the follower and floorplate and adding us made furniture

inner ordinance was making such crappy aks they would chop their receivers up and sell them as parts kits

[L84CABO]

I have yet to hear of an individual builder actually cited. However, the ATF has responded (in the past) to requests from individual builders and the ATF clearly seems to believe 922R is relevant.

Here is the address for ATF for inquiries on 922R per Freedom Fighter Tactical's website. Shoot them a letter on what you're contemplating doing to your gun and see what they say...or not. But if you do, let us know what the say.

Chief, Firearms Technology Branch
Bureau of Alcohol, Tobacco, and Firearms
Firearms Technology Branch
244 Needy Road
Martinsburg, WV 25401

https://freedomfightertactical.com/pages/922r-faq

[-hanko]

ah the good old 10 parts rule yea i have never heard of any individual being charged but i was extra careful when i upgraded my mak90 back in the 90s
anyone remember replacing the follower and floorplate and adding us made furniture

inner ordinance was making such crappy aks they would chop their receivers up and sell them as parts kits

No requirement to mark parts "USA" or similar. IO chopped their receivers per BATFE requirements...it was that or send the guns back to where they were purchased.

[-hanko]

I have yet to hear of an individual builder actually cited. However, the ATF has responded (in the past) to requests from individual builders and the ATF clearly seems to believe 922R is relevant.

Here is the address for ATF for inquiries on 922R per Freedom Fighter Tactical's website. Shoot them a letter on what you're contemplating doing to your gun and see what they say...or not. But if you do, let us know what the say.

Chief, Firearms Technology Branch
Bureau of Alcohol, Tobacco, and Firearms
Firearms Technology Branch
244 Needy Road
Martinsburg, WV 25401

https://freedomfightertactical.com/pages/922r-faq

See above response...no requirement to identify parts with country of origin.

[-hanko]

I have yet to hear of an individual builder actually cited. However, the ATF has responded (in the past) to requests from individual builders and the ATF clearly seems to believe 922R is relevant.

Here is the address for ATF for inquiries on 922R per Freedom Fighter Tactical's website. Shoot them a letter on what you're contemplating doing to your gun and see what they say...or not. But if you do, let us know what the say.

Chief, Firearms Technology Branch
Bureau of Alcohol, Tobacco, and Firearms
Firearms Technology Branch
244 Needy Road
Martinsburg, WV 25401

https://freedomfightertactical.com/pages/922r-faq

FFT depends on you believing the BATFE cares about an individual's paranoia in regard to 922(r). That's how they survive as a business, granted a BS business.

Otoh, I believe in following the money. FFT depends on your thinking that 922(r) applies to an individual gun owner. The BATFE has demonstrated over the years that it does not.

[Milsurp1]

https://trac.syr.edu/tracreports/crim/492/

[SVT-40]

Whenever I build, I make my rifles 922r compliant. It's not a big deal. Today most "builds" use many US made parts anyway..

Most AK's are now built with the following US made parts. All you need is one additional part to be in compliance. That could be having a foreign made magazine with a US made follower or base plate.

Or another US made part.

Receiver
barrel
trigger
hammer
disconnector


I use the below site to verify compliance.

http://thegunwiki.com/Gunwiki/BuildAkVerifyCompliance

As per an ATF letter located (below), magazine parts are not subject to constructive possession. If you need US-made magazine parts in order to reach 10 or fewer imported parts, then you don't have to replace parts on all of your magazines - only the ones which you intend to use with this rifle.

http://thegunwiki.com/pub/Gunwiki/LegalFederal922rParts/BatfeRochte1.jpg

http://thegunwiki.com/pub/Gunwiki/LegalFederal922rParts/BatfeRochte2.jpg

[L84CABO]

FFT depends on you believing the BATFE cares about an individual's paranoia in regard to 922(r). That's how they survive as a business, granted a BS business.

Otoh, I believe in following the money. FFT depends on your thinking that 922(r) applies to an individual gun owner. The BATFE has demonstrated over the years that it does not.

This is exactly why I said contact ATF directly. Don't take the internet's word for it either way. See what the horse has to say and then the OP can make his own decision.

With that said, ATF has responded to individuals in the past. If they have since indicated that they no longer care about 922R, then please link us to some of these instances.

[Verdha603]

Whenever I build, I make my rifles 922r compliant. It's not a big deal. Today most "builds" use many US made parts anyway..

Most AK's are now built with the following US made parts. All you need is one additional part to be in compliance. That could be having a foreign made magazine with a US made follower or base plate.

Or another US made part.

Receiver
barrel
trigger
hammer
disconnector


I use the below site to verify compliance.

http://thegunwiki.com/Gunwiki/BuildAkVerifyCompliance

As per an ATF letter located (below), magazine parts are not subject to constructive possession. If you need US-made magazine parts in order to reach 10 or fewer imported parts, then you don't have to replace parts on all of your magazines - only the ones which you intend to use with this rifle.

http://thegunwiki.com/pub/Gunwiki/LegalFederal922rParts/BatfeRochte1.jpg

http://thegunwiki.com/pub/Gunwiki/Le...tfeRochte2.jpg

At least with regards to AK builds I usually recommend the parts you already mention and a US made muzzle device to meet 922r compliance. Plenty of US companies make their version of the original slant muzzle brake for 5 to 10 bucks and if the end user decides they want something different, chances are they'll find it amongst the various US made muzzle devices.

[AR22]

Problem is some parts are just not available for some Builds. Cetmes are one case where it is very difficult to find enough US made parts. The whole thing is simply another government sham, no one really cares about it anyway. I sure would not lose any sleep over it.

If you were to be caught for some other serious crime, and they really wanted to have a add on. They may charge someone with 922R to stick it to em better. But the regular law abiding Joe will never have to answer for it in a normal course of life.Fact is the ATF knows they will be laughed at when questioned by a judge, when asked to explain all this in a court of law. They have I believe even avoid this scenario buy dropping a case, rather than look like *** hats if it went to court.

The ATF has admitted before, they cannot know themselves if a part was USA made or not. Not really a provable point.

[-hanko]

This is exactly why I said contact ATF directly. Don't take the internet's word for it either way. See what the horse has to say and then the OP can make his own decision.

With that said, ATF has responded to individuals in the past. If they have since indicated that they no longer care about 922R, then please link us to some of these instances.

A link to one letter... ATF 922(r) letter from the FAL Files

Snippets I found interesting...

922(r) forbids manufacturing a firearm, but it does not prohibit possession of an assembled weapon without the required number of U.S. parts.

Removing parts for routine cleaning and maintenance and reassembling the weapon is not prohibited...you tell me the your definition of maintenance.

Since identifying the parts by part number and/or country of origin is not required, imo all bets are off. OT, DSA was selling what they called U.S. fire control parts, basically everything from trigger to firing pin. A guy on the FAL Files bought a few. Turns out he was a university prof in materials science at a very good engineering school. His analyses indicated DSA's parts had an identical material alloy to Imbel parts. Deny, deny, deny from DSA, but they stopped selling the parts.

Government also noted they really had no processes in place to verify U.S. or foreign parts manufacture.

Problem is some parts are just not available for some Builds. Cetmes are one case where it is very difficult to find enough US made parts. The whole thing is simply another government sham, no one really cares about it anyway. I sure would not lose any sleep over it.

If you were to be caught for some other serious crime, and they really wanted to have a add on. They may charge someone with 922R to stick it to em better. But the regular law abiding Joe will never have to answer for it in a normal course of life.Fact is the ATF knows they will be laughed at when questioned by a judge, when asked to explain all this in a court of law. They have I believe even avoid this scenario buy dropping a case, rather than look like *** hats if it went to court.

The ATF has admitted before, they cannot know themselves if a part was USA made or not. Not really a provable point.

[george223]

Interesting. When I built a couple of AK's a few years ago, I went out of my way to get US made parts to comply with 922r. I was concerned that some of the parts had no markings on them so how could I convince somebody that they were made in the USA. It's been awhile since I thought about this and can't remember details about 922r or which parts were of concern.

Thanks for the info. I can rest a little easier now.

[The War Wagon]

ah the good old 10 parts rule yea i have never heard of any individual being charged but i was extra careful when i upgraded my mak90 back in the 90s
anyone remember replacing the follower and floorplate and adding us made furniture

U.S. furniture and a muzzle brake, and 30 rd. Chinese mags all day!

Of course, I was living in NC then, too.