For those who get into the world of battle rifles - particularly AK-style - you're going to find yourself having to deal with Federal regulations. Specifically, compliance with 18 USC 922R.

There's lots of debate about what is and is not covered under 922R. I am not a lawyer, but I'm going to present my layman's understanding and interpretation of the compliance requirements. These are my opinions only -- and I don't encourage anyone to take a legal stand based on them.
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What is 922R?

Title 18 of the US Code (18 USC), Chapter 44 Section 922 provides guidance on unlawful acts as they relate to firearms.  You can read the text of the law by clicking here.

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. "


Most of us don't fall under those exceptions, so we are left to deal with meeting compliance with the law.

"Sporting" Purposes
Here's where things get a little tricky. Some rifles, such as the Saiga line, are imported for sporting purposes in a particular configuration. Generally, that means that do not incorporate any of the "evil" features that are typically associated with so-called "semi-automatic assault weapons".  Chapter 27 of the Code of Federal Regulations Section 478.11 defines these SAWs. You can read the law, here. Specific examples of these features include:

- High capacity (greater than 10 round for rifles, 5 rounds for shotgun) magazines
- Pistol grip attachment
- Folding buttstock
- Muzzle device/attachment (to include a threaded barrel capable of receiving a device)
- Bayonet lugs
If your rifle or shotgun incorporates those features, it no longer is considered "suitable  for sporting purposes".

Assembling Semiauto Rifles and Shotguns
If your rifle or shotgun is subject to 922R, you must now make sure that it is in compliance with the regulations governing the assembly of semiautomatic rifles and shotguns. That is covered in Title 27 Chapter 1 Section 178.39. Click here to see the text of the law.  It states :

(a) 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.

Paragraph (C) defines the following parts as "countable" under the law:
(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) Buttstocks *
(16) Pistol grips *
(17) Forearms, handguards *
(18) Magazine bodies *
(19) Followers *
(20) Floorplates *

These 20 items are referred to with the term "compliance parts". There are lots of other components that go into a weapon, but there are the only ones that count in terms of complying with the law.

The 16 items marked with an asterisk are the parts that are generally found on a standard AK 47. The Saiga sporter rifle, as imported, does not have a muzzle device or pistol grip, so it has 14 countable parts. A Saiga shotgun has 13 countable parts (the trunnion is considered part of the receiver) - 14 if the barrel is threaded.

So once you have done something to take your rifle or shotgun out of a "sporting" configuration, you must now make sure that your weapon has no more than 10 of these parts that are imported.

Complying with 922R
Now the trick is making your weapon compliant with the law. To do that, you will need to replace 3 to 6 of the existing parts with components made in the US.

Here are the parts that most owners use to achieve 922R compliance:
- Trigger
- Hammer
- Disconnector
- Buttstock
- Pistol grip
- Handguard (upper and lower handguards on an AK only count as 1 compliance part)
- Gas piston
- Magazine parts (Note: body, follower and floorplate each count as 1 compliance part).

So you can see that there are plenty of ways to achieve 922R compliance. Personally, I think relying on magazine parts to meet compliance is risky: if someone puts a foreign-made magazine in your weapon, you are now in violation of Federal law. Better to use the other parts for compliance and save the magazines as a "nice to have" compliance option.

Calculating Compliance

How you figure your compliance is up to you. Some people just count up the number of foreign parts and make sure it's less than 10. They don't consider any added parts if they are US-made. Personally, I prefer to start with the total number of compliance parts in my rifle/shotgun, then work backwards.  To me it's safer, in the event that somewhere down the road you change out one part for another.

Here's an example: I have a Saiga AK with pistol grip and muzzle device. Using the guidelines for countable parts, that gives me 16 parts. In order to be compliant, I must have at least 6 US-made parts in my rifle. My rifle has the following US parts:
Trigger, Hammer, Disconnector, Compensator (muzzle device), Gas piston, magazine floor plate and magazine follower. That gives me 6 parts and means I am complying with the law.

You'll notice that I broke my own rule about using magazine parts. That's because the buttstock and pistol grip I ordered turned out to be made in Israel, so they do not count as compliance parts. Unfortunately, they are so well-made and comfortable that I don't want to replace them! I also had the stock Saiga handguard customized, so it doesn't count for my compliance either.

On my Saiga shotgun, I had 14 countable parts. In order to meet compliance, I installed the following US-made parts:
Hammer, trigger, disconnector, buttstock, pistol grip, external choke (muzzle device), US-made magazines.

That gives me a total of 9 US-parts -- and I only need 4. So while I have US mags to use, I'm not limited to them like I am with my Saiga rifle.

Special Saiga Considerations

The Saiga rifle is imported in a sporter configuration and thus is not subject to 922R compliance. That is....until you decide you want to use high capacity magazines! If you plan on doing a full AK conversion, then there's generally no problem -- the conversion parts (fire control group, buttstock, pistol grip) usually take care of compliance.

Some people, though, want to keep the sporter configuration but use high caps - and that takes a little more creativity. There are 14 countable parts in the Saiga sporter (no pistol grip or muzzle device).

Quick compliance parts include:
- Handguard: TAPCO makes an AK-specific, Galil-style handguard (1 compliance part)
- Gas piston: US-made gas piston (either AK 47 or AK 74) (1 compliance part)
- Trigger: You can modify a TAPCO G2 trigger to work in the stock Saiga firecontrol group (requires grinding and cuttting) (1 compliance part)
- Hammer: You can install a TAPCO G2 hammer in the stock FCG (1 compliance part)
- Magazines: Complete US made mags (like ProMag or Thermold) or US followers and/or floor plates in foreign magazine bodies (1-3 compliance parts)

Another popular "quasi conversion" is to use the ACE Saiga receiver block/pistol grip combo, like this. This gives you an AK-like grip/buttstock without having to move the FCG. Adding the pistol grip ups your parts count to 15. Since ACE equipment is US-made, the buttstock and pistol grip each count as 1 part. That means you only need three more (from the list above) to be compliant.

Be aware that there is also a Russian-made version of the same block/grip combo. You can use it, but you then have to find 5 replacement parts to be compliant.

There are also two kinds of Surefire magazines designed for the Saiga rifle. There are all-plastic ones that are US-made and count for compliance. The older versions are metal bodies, and although Surefire is a US company, the magazines use foreign parts and do not count for 922R compliance!





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