922r question, building a PSL, parts count applies?

[diddler]

I've had these questions knocking around in my head for the last few months, kind of hoped that the answers would fall into place but they're not. Seems like there is a lot of conflicting information/opinions on the topic.

Here goes: At some point in the near future I hope to assemble a Romak III/PSL parts kit I picked up from Centerfire. I know that in the past the PSL has been imported as a "Sporting" type rifle (no pistol grip, thumbhole instead, no large capacity mags, no bayonet lugs, etc) and therefore didn't have to follow the 922r parts count games. Here is where things start getting muddy.

First question: This -type- of rifle has been imported as a sporting rifle, but my specific rifle was (presumably) imported not as a rifle but just as a collection of parts. It will be assembled by me, here in the USA. Right there, does that mean I MUST follow 922r parts count? Or, if it is assembled using the identical types of parts on the imported sporting rifle would it still be 922r exempt?

Second, I've heard it claimed that if you replace ANY part on the rifle you are effectively the builder/assembler (forgive the possibility this isn't the correct legal term) and the weapon would have to them become 922r compliant. I've even seen an official letter response from the BATF where this area is (deliberately?) fuzzy. Some people seem to think that if you replace a screw, or a broken spring it's no longer "as imported", BAM!, 922r.

Others seem to think that it this would apply only if you modify one of the parts/features that made it a "sporting rifle" in the first place, ie: you remove the thumbhole stock and install a pistol grip. This seems probable, and almost logical by the standards of the powers that be.

Some specific changes I'm considering: I'm strongly leaning towards using the Nodak US made receiver for the PSL. With regards to the functioning of the weapon it's identical to the original Romanian receiver. Consider a simple scenario: I had one of these pre-built imported PSL Sporting rifles, all Romanian parts. I replace ONLY the receiver with this functionally identical US made receiver. Would it now need to adhere to 922r?

Another one: As much as I like the reviews I'm reading on the Nodak receiver it has one primary design change from the original Romanian that I'm not a fan of. Rather than using the original thumbhole stock the Nodak receiver is designed to use standard AK furniture, ie: separate stock and pistol grip. I like to look of the skeletonized PSL thumbhole stock. To retain the look I intend to use a Romanian WASR thumbhole stock attached to the Nodak receiver. Their fit, function and look are nearly identical, and both from the same country. Ignoring for the moment the use of the the US made receiver, I'm replacing the Romanian-made PSL thumbhole stock with the Romanian-made WASR thumbhole stock. 922r Kosher, or 922r Foul?

Despite the fact that (virtually?) nobody is prosecuted for 922r offenses I want this thing legal. I'm guessing that regardless of the law there would be enough grey area where I'm going to just bite the bullet (no pun) and just tack on some more US made parts, if for no other reason than I just can't stomach butchering off the near useless bayonet lugs just to make it functionally identical to the "as imported sporting condition". I just wish this all made more sense. As it stands it's as clear as mud. Anyone have some definitive answers?

Thanks all. I hope this makes some sense, it's a jumble in my head.

[Rascal]

You can assemble the rifle with all foreign parts IF you don't have any non sporting features on it. i.e no pistol grip,flash suppressor, bayonet, night sights. See 922r for full list.
922r ONLY refers to foreign made weapons. Foreign made weapons can not have "non sporting" features. You cannot assemble, make, manufacture foreign made weapons with "non sporting" features, BUT if the weapon has enough U.S.A. made parts, it is considered made in the U.S.A. and CAN have "non sporting" features. How do you know what parts count as U.S.A. parts?
922r tell you what the parts are.
Here is the list:
Receiver
Barrel
Front Trunnion
Rear Trunnion
Muzzle Attachment
Bolt
Bolt Carrier
Gas Piston/Puck
Trigger
Hammer
Disconnector
Buttstock
Forearm/Handguard
Pistol Grip
Magazine Body
Magazine Follower
Magazine Floorplate
This is a total of 17 parts

Having more than 10 of these foreign parts in your weapon, means that it is a foreign made weapon, and IS SUBJECT to 922r regulations.

If you were to replace enough foreign made parts in your weapon, then the weapon IS considered a U.S.A. made weapon, and is therefore NOT SUBJECT to 922r regulations.

What's available for me to replace?


Receiver
Muzzle attachment If you don't have a threaded barrel, there's
no attachment so this doesn't count.
Gas piston
Trigger
Hammer
Disconnector
Buttstock
Pistol grip
Forearm, handguard
Magazine body
Follower
Floorplate
Total of 12 parts that are available from various vendors here in the States.

Replace any 10 of the above parts with U.S.A. made parts and your weapon is now considered a made in U.S.A. weapon. You can now have "non sporting" features and still satisfy Federal Law.

Just remember that this is California and if you have a pistol grip, you can't have a detachable magazine or you can't have a non detachable magazine that holds more than 10 rounds. You must comply with SB23.

[Mssr. Eleganté]

...First question: This -type- of rifle has been imported as a sporting rifle, but my specific rifle was (presumably) imported not as a rifle but just as a collection of parts. It will be assembled by me, here in the USA. Right there, does that mean I MUST follow 922r parts count? Or, if it is assembled using the identical types of parts on the imported sporting rifle would it still be 922r exempt?

If you assemble it into an importable "sporting" configuration then you don't need to worry about replacing any parts. Just make sure that the version you are copying that you think is "imported" is really not just a rifle that Century has already played the 922(r) 10 parts game with.

Second, I've heard it claimed that if you replace ANY part on the rifle you are effectively the builder/assembler (forgive the possibility this isn't the correct legal term) and the weapon would have to them become 922r compliant. I've even seen an official letter response from the BATF where this area is (deliberately?) fuzzy. Some people seem to think that if you replace a screw, or a broken spring it's no longer "as imported", BAM!, 922r.

A non-C&R firearm doesn't have to stay "as imported" to avoid the 922(r) 10 parts game. It just has to stay "importable".