922r AR-15

[morrcarr67]

I have a question about 922r compliance when it comes to the AR platform.

How many of the the 922r parts are in an AR?

To help with the counting here's the list:

For purposes of this section, the term imported parts are1) Frames, receivers, receiver castings, forgings or stampings
(2) Barrels
(3) Barrel extensions
(4) Mounting blocks (trunions)
(5) Muzzle attachments
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors
(15)*Butt stocks
(16) Pistol grips
(17) Forearms, hand guards
(18) Magazine bodies
(19) Followers
(20) Floor plates

To make it a little more interesting I'd like to see what you think about the "trigger housing". Does that mean the part that surrounds the exposed part of the trigger? If it does if you're using a new style billet lower with the "trigger guard" machined as a completely closed part of the frame does that mean it no longer has a separate "trigger housing"?

Here are a couple of pictures of milspec and billet lowers for review.



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[ugimports]

What do you plan to use that's not US made? That might be easier to figure out if 922r even comes into play.

I've never heard anyone consider it for US made firearms. How many foreign companies are making key AR parts?

[morrcarr67]

What do you plan to use that's not US made? That might be easier to figure out if 922r even comes into play.

I've never heard anyone consider it for US made firearms. How many foreign companies are making key AR parts?

I work for a company that makes 7 of the controlled items listed in 922r that are not made in the US. We also make many more none controlled items.

All manufactures must consider 922r.

Sec. 178.39 Assembly of semiautomatic rifles or shotguns.

No person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph (c) of this section if the assembled firearm is prohibited from importation under section 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes.

All AR Style rifles sold in the US are made in the US because they can't be imported under 925(d)(3)

, and must be of a type generally recognized as particularly suitable for or readily adaptable to sporting purposes.

Handguns

Pistols & revolvers must meet size & safety requirements and accrue a qualifying point value specified on ATF F 5330.5 (Form 4590), Factoring Criteria for Weapons.

Rifles and Shotguns

Firearms such as single shot, lever action, bolt action and certain semiautomatic long guns with generally recognized sporting features.

Note: ATF has determined that certain features designed for military application are indicative of non-sporting rifles and shotguns. Features which are not recognized as sporting include, but are not limited to, folding or telescoping stocks, pistol grips that protrude conspicuously beneath the action of the weapon, a bayonet or bayonet mount, a flash suppressor or threaded barrel designed to accommodate a flash suppressor, a grenade launcher and night sights. These features as well as other information concerning a particular firearm may result in ATF classifying a rifle or shotgun as non-sporting. Additional information regarding this subject is available in the Report and Recommendation of the ATF Working Group on the Importability of Certain Semiautomatic Rifles or The Department of Treasury Study on the Suitability of Modified Semiautomatic Assault Rifles.

[ugimports]

I work for a company that makes 7 of the controlled items listed in 922r that are not made in the US. We also make many more none controlled items.

All manufactures must consider 922r.

I get that.. my point is I'm not aware of any US made ARs where they are using any of the 7 controlled items your company makes. That's why I was asking.

In regard to 922r and your original question I'm not sure if the lower counts or if trigger housing would refer to the drop in triggers and the piece that holds the assembly together.

[morrcarr67]

I get that.. my point is I'm not aware of any US made ARs where they are using any of the 7 controlled items your company makes. That's why I was asking.

In regard to 922r and your original question I'm not sure if the lower counts or if trigger housing would refer to the drop in triggers and the piece that holds the assembly together.

I am. We are not a firearms manufacturer. We sell all the stuff we make to firearm manufacturers here. We have 5 really large customers that buy from us as well about 40 midsize firearms manufacturers. And you would know the names of the companies if I told you. The largest is located in Florida.

And we're not the only company bringing in parts from overseas for these and other OEM customers.

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[ugimports]

This may be a stupid question, but can't you ask one of your customers since they clearly have to worry about this?

[morrcarr67]

Well we could, but we don't want to raise any red flags. We spent about 5 months working on a really large customer; I'd say in the top 5, and they really like the product we were trying to sell them. Problem is they just don't want import on a 922r regulated part.

So, the owner of the company is betting on the come. He just signed a contract for almost $400,000 to get brand new cnc machines and a really high tech lathe to be installed in our location here so we can make US made parts. But he's thinking that with that big of investment he might as well build rifles too.

Which is why I'm asking other people.

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[ugimports]

BTW: you can also contact the ATF. They are generally pretty helpful.

[morrcarr67]

Doh, why didn't I think of that.

BTW: you can also contact the ATF. They are generally pretty helpful.

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[SVT-40]

I have a question about 922r compliance when it comes to the AR platform.

How many of the the 922r parts are in an AR?

To help with the counting here's the list:



To make it a little more interesting I'd like to see what you think about the "trigger housing". Does that mean the part that surrounds the exposed part of the trigger? If it does if you're using a new style billet lower with the "trigger guard" machined as a completely closed part of the frame does that mean it no longer has a separate "trigger housing"?

I don't think AR type firearms have "trigger housings". The trigger is "housed" and contained in the receiver.


Just because the list of 922r parts specifies "trigger housings" does not mean every firearm has a "trigger housing".

Now maybe a drop in type trigger, hammer assembly would be contained in a "trigger housing"...

However if they are that may eliminate them from being individually listed as a specific part...

[Addax]

Morcarr

If you are making the parts outside of the US (bolts, bolt, barrels, carriers, trigger, hammer etc) or importing to be sold to manufacturers here in the US who are using them in their US made firearms, then 922r compliance can indeed be a concern for them. If an ATF agent during an inspection asks for records of where parts were made and asks for proof that could turn into a potential issue for the gun manufacturer who is buying parts made overseas and using them in US manufactured guns.

When Surplus AK rifles were chopped up into parts kits and shipped/imported to the US, US Gun Companies building AK rifles here in the US used these kits but also had to comply with 922r. Essentially the same thing as you describe with certain US gun manufacturers buying your foreign made parts which are then used in US made guns.

[morrcarr67]

I don't think AR type firearms have "trigger housings". The trigger is "housed" and contained in the receiver.


Just because the list of 922r parts specifies "trigger housings" does not mean every firearm has a "trigger housing".

Now maybe a drop in type trigger, hammer assembly would be contained in a "trigger housing"...

However if they are that may eliminate them from being individually listed as a specific part...

I got the same answer from someone else on a different forum. We figured that there are 16 922r controlled parts in a milspec AR style rifle.

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[morrcarr67]

Morcarr

If you are making the parts outside of the US (bolts, bolt, barrels, carriers, trigger, hammer etc) or importing to be sold to manufacturers here in the US who are using them in their US made firearms, then 922r compliance can indeed be a concern for them. If an ATF agent during an inspection asks for records of where parts were made and asks for proof that could turn into a potential issue for the gun manufacturer who is buying parts made overseas and using them in US manufactured guns.

When Surplus AK rifles were chopped up into parts kits and shipped/imported to the US, US Gun Companies building AK rifles here in the US used these kits but also had to comply with 922r. Essentially the same thing as you describe with certain US gun manufacturers buying your foreign made parts which are then used in US made guns.

Yeah, I'm pretty sure they know that. We make 7 of the 20 items listed. Not one customer buys more than 3 of the 7. I think they want to stay on the right side of 922r.

I'm thinking that once we get the US facility up and running we won't have anything to worry about when it comes to 922r if we decide to get into rifle manufacturing.



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[SVT-40]

I've wondered what "US" made actually means?

If a "part" is forged in another country and finished in the US is it a "US" made part?

What % of the work on a part allows it to be labeled as a "US" made part?

[morrcarr67]

I've wondered what "US" made actually means?

If a "part" is forged in another country and finished in the US is it a "US" made part?

What % of the work on a part allows it to be labeled as a "US" made part?

It all depends.

Let's say that you make aluminum handguards and barrel nuts overseas and ship them to the US in the white to be finished. So now they're here, you anodize the handguard and apply what ever finish to the barrel nut and put them in a retail package.

When all is said and done if you figure that it cost you $30 from start to finish. If you can prove that you spent at least $15.01 in the US to get to the end product you can say that it was made in the USA.

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