922R:  Benelli M1018:  

​922r prohibits increasing the magazine capacity on the Benelli M4 shotguns from 5 rounds to any more than 5 rounds or the installation of a collapsible stock.   The Benelli M4 may not contain more than 10 imported parts from that list , therefore, 3 parts must be removed and replaced with American made parts.


Bringing the M4/M1018 into 922r compliance allows individuals to add additional magazine capacity and collapsible stocks to the M4/1018.


3 imported parts must be replaced with 3 US made parts on the Benelli M4/1018  

Which parts may be replaced on the Benelli M4 to comply with 922r? 

Receiver
Barrel
Bolt
Bolt carrier
Gas piston
Trigger housing
Trigger
Hammer
Disconnector
Buttstock (with integral pistol grip)
Forearm/handguard (forend)
Magazine body
Follower



“magazine body” - the magazine tube. installation of a full length magazine tube counts as one part.


The three parts must be made in the US and totally replaced. The installation of a magazine EXTENSION does not count towards 922(r) compliance. To use the EXTENSION, the user must still replace a total of three other parts off that list in order to be compliant with 922r. 

It is presumed that the Benelli M4 is using the Benelli OEM stock or an aftermarket stock, and NOT the Benelli M4 collapsible stock.


If the Benelli brand collapsible stock is used, it increases the 922(r) part count by one, Therefore, a total of four (4) other parts would have to be replaced with US made parts to be compliant with 922r.  The OEM Benelli M4 stock is a stock with an integrated pistol grip. The Benelli collapsible stock is 2 parts.  The stock as one and the pistol grip as another.


Benelli M4/1018 Parts:

Here is the list of 922r parts:  The ones in Blue are M1018/M4 parts.

(1) 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 (x2) 
(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 


In my personal research, I have noted that there are several BATE opinion letters circulating with differing parts lists.  

922R:  AK Series Rifles:  AK or Saiga, you’ll likely be looking at replacing three to six parts (to U.S. manufactured parts) to comply iwth 922r.  


Consider this:   are you modifying a 922r compliant AK?  Changing a single part could make the firearms non 922r compliant.

The parts most often selected to reach 922R compliance:

1.  Trigger
2.  Hammer
3.  Disconnector
4.  Buttstock
5.  Pistol grip
6.  Handguard (upper and lower handguards on an AK only count as one compliance part)
7.  Gas piston
8.  Magazine parts— This is a 3 for 1:  body, follower and floorplate each count as one compliance part.  


CONSIDER:  Swap a US magaine with a foreign magazine or get caught with the wrong magazine, and the firearm is no longer compliant with 922r.

Type your paragraph here.

MKE AT-94P has 11 foreign made parts on it and no US made parts.


Anyone thinking of converting a 94P into a carbine must replace one foreign part and add five US parts to make it 922r compliant.


Add

1.   a US made stock,

2.  forearm,

3.  pistol grip,

4.  trigger,

5.  hammer and

6.  sear. 

922R:  H&K UMP:  

The USC has 13 of the imported parts on the list.   Therefore, you must replace 3 foreign parts with 3 US made parts to make a UMP 922r compliant, 


(1) Frames, receivers, receiver castings, forgings or stampings
(2) Barrels

(3) Barrel extensions
(4) Mounting blocks (trunnions)
(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) Buttstocks
(16) Pistol grips

(17) Forearms, handguards 
(18) Magazine bodies 
(19) Followers
(20) Floorplates


Here is the ATF list for HK UMP systems

Receiver
Barrel
Mounting Block
Bolt Carriers
Cocking Handle
Trigger Housing
Trigger
Hammer
Sear
Butt Stocks
Pistol Grips
Magazine Housing
Magazine Followers
Magazine Floor Plates


So, if you wanted to keep original HK barrels in your UMP - for a .45 and a .40? 
For .45 - trigger/follower/floor plate?
For .40 - trigger/sear/floor plate?


Some interesting combinations:


Option #1 HDPS conversion with real UMP stock

Parts you will need
- H&K USC
- H&K UMP lower receiver
- H&K UMP stock
- HDPS rear stock block B (stock block B can only be used for UMP stocks)
- UMP magazine
And any three of the following
- HDPS barrel
- HDPS trigger
- HDPS mag follower
- HDPS mag floor plate

Option #2 HDPS conversion with a US made stock

Part you will need
- H&K USC
- H&K UMP lower receiver
- HDPS rear stock block C (stock block C is for non UMP stocks)
- UMP magazine
And any three of the following
- US made stock (ACE or **AR type stock)
- HDPS barrel
- HDPS trigger
- HDPS mag follower
- HDPS mag floor plate

Option #3 HERA UMP style conversion

Parts you will need
- H&K USC
- HERA UMP conversion stock/grip
And any three of the following
- HDPS barrel
- HDPS trigger
-*Here is where the problem is…….there is no third part available.


Option #4 HERA AR stock and grip conversion 

Parts you will need
- H&K USC
- HERA AR stock and grip conversion 
And any three of the following
- US made AR style stock
- US made AR style grip 
- HDPS barrel
- HDPS trigger


* remember the HERA system uses the USC mages, and no one is making US made 
followers and base plates for them.


​Option #5 TN UMP Conversion

Parts you will need:
- H&K USC
- H&K UMP lower receiver
- H&K UMP magazine
- TN stock block
- TN US made UMP stock
- TN US trigger
- TN US Sear

Saiga 12 Shotgun: 
b) A semiautomatic Shotgun that has an ability to accept a detachable magazine and has at least 2 of— 

But which 2 of these does it have? 

(1) A folding or telescoping stock, 
No 

(2) A pistol grip that protrudes conspicuously beneath the action of the weapon, 
Yes 

(3) A bayonet mount, 
No 

(4) A flash suppressor or threaded barrel designed to accommodate a flash suppressor, and 
Yes

(5) A grenade launcher; 
No 


If you want to use standard capacity magazines, convert the weapon to pistol grip configuration or use a flash hider, it will then be considered unsporting. You will need to swap out parts so that you have no more than 10 imported parts in it. It will then be considered a US made firearm and 922 does not apply. See bottom of this post for more 922 info and some grey areas.


A Saiga Rifle in factory configuration has 14 parts.
A Saiga shotgun threaded for chokes has 14 parts.
A Saiga shotgun not threaded for chokes has 13 parts.

(parts on a factory config saiga are in bold)


Saiga 12 Parts

(1) Receiver 
(2) Barrels 

(3) Barrel extensions 
(4) Mounting blocks, trunnion (rifles only) 
(5) Muzzle attachments (shotguns w/ threaded barrels only) 
(6) Bolts 
(7) Bolt carriers
 
(8) Operating rods 
(9) Gas pistons 
(10) Trigger housings 
(11) Triggers 
(12) Hammers 

(13) Sears 
(14) Disconnectors 
(15) Buttstock 
(16) Pistol grips 
(17) Forearms, handguards 
(18) Magazine bodies 
(19) Followers 
(20) Floorplates

922R:  What is it?  The law controls manufacture, importation or re-assembly of a "nonsporting" weapon.


No more than 10 foreign made parts allowed out of 20 enumerated parts for semiautomatic firearms that are imported into the United States.


 
Title 18 Chapter 44 Section 922(r) of the United States Code, defined further by Title 27 Part 478.39 of the Code of Federal Regulation (CFR), restricts semiautomatic rifles and shotguns to no more 10 imported parts from a list of 20 parts.


 Section 922 Paragraph R states:

“It shall be unlawful for any person to assemble from imported parts any semiautomatic rifle or any shotgun which is identical to any rifle or shotgun prohibited from importation under section 925(d)(3) of this chapter as not being particularly suitable for or readily adaptable to sporting purposes except that this subsection shall not apply to:
(1) the assembly of any such rifle or shotgun for sale or distribution by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
(2) the assembly of any such rifle or shotgun for the purposes of testing or experimentation authorized by the Attorney General.”

Lets clarify, 922r. A simple evaluation of your semi automatic firearms allows you to ensure your firearms are compliant with 922r.

Simply put, it is unlawful for a semi-auto rifle or shotgun to have more than 10 imported parts from the enumerated list of 20 parts. Many describe this in terms of U.S. parts count.  A correct statement is that this should be the foreign parts count.


Lets look at the 20 parts enumerated in 27 C.F.R. 478.39

27 C.F.R. 478.39 lists 20 parts: 
(1) 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) Floorplates


922r states that you can have NO MORE THAN 10 imported parts, of these 20 listed parts, on a semi-automatic rifle or shotgun that does not have a sporting pup[ose. These 20 parts apply to all firearms that are imported and not all imported firearms are the same.  


Lets look at some specific examples:

922R:  CZ EVO Skorpion:


​SBR, you must reduce the number of imported parts from 15 (in pistol form it had 15 since there’s no imported stock on it) to 10 or less.   Therefore, to make the CZ Skorpion 922r compliant you must replace five foreign parts with US made parts.

1.  muzzle device - U.S.-made suppressor mount

2.  Magazines  - aftermarket or for CZ-USA itself to manufacture magazines in the US. (3 parts),

    a.  Body

    b.  Follower

    c.  Floorplate

3.  fire control groups (4 parts), 

4.  pistol grip (1 part),

5.  Folding stock

Call Today: +1.2814514175

Sean Cody

Beretta Cx4 is: 
b) A semiautomatic rifle that has an ability to accept a detachable magazine and has at least 2 of the following:

But which 2 of these does it have? 

(1) A folding or telescoping stock, 
No 

(2) A pistol grip that protrudes conspicuously beneath the action of the weapon, 
Maybe, what's the current ATF position? 

(3) A bayonet mount, 
No 

(4) A flash suppressor or threaded barrel designed to accommodate a flash suppressor, and 
No 

(5) A grenade launcher; 
No 



So, the Beretta CX-4 parts are:


1.  Receiver
Barrel
Bolt
Trigger housing
Trigger
Hammer
Buttstock (pistol grip seems to be integral)
Magazine body
Magazine floorplate
Magazine follower
Charging handle
Disconnector (maybe? it's not named that if it has one)

That's 12 parts. If you replace the magazine with a Checkmate USA one it will drop the imported parts count by 3, leaving you with 9. The legal limit is 10 so even if we miscounted by 1 you would still be able to thread the muzzle and attach a US made muzzle device and be in compliance.

It may be adviseable to call Beretta and ask which parts are imported and counted by 922r, then replace enough to reduce the numberr to 10.

Has anyone been prosecuted for a 922r violation?   Most criminal prosecutions for 922r have been against licensed (FFL 07) manufacturers. 


Do I have to comply with 922r if I register my firearms as a SBR?  In light of the latest round of letters from ATF, it appears you have to get the foreign parts count down to 10 or fewer if you want to run standard capacity magazines, threaded barrels and folding or collapsible stocks and pistol grips

on an imported rifle. Even if you SBR it.


Do the U.S. made parts that replace the foreign parts have to be stamped "Made in the US?"? 

A vender stated that  ATF agents at the SHOT Show stated that it is not necessary that the parts are stamped with marks identifying the part as made in the USA,


Neither th law nor the CFR requires that replacement parts be stamped as made in the U.S>  


My personal opinion is that it isn't a bad idea where possible. 


Can I be prosecuted if I purchase a rifle or shotgun is not 922r compliant?  

1.  It only applies to assembly. That said, the BATFE defines assembly as changing a minimum of ONE part.


NOTE: Removing and inserting a different magazine does not mean assembly per the BATFE.

2.  There is no criminal penalty for possessing a 922(r) non-complaint rifle. That said, the BATFE has not ruled whether a non-compliant rifle is contraband subject to confiscation.