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922r Compliance

Parts Count on Saigas

First and foremost, I’m not a lawyer. This is my attempt to express my understanding of the current laws and how they apply to the Saiga firearms.

Before doing anything, check with your local and state laws as you may have tighter regulations than what the ATF has laid out for the rest of us.

The Saigas have a certain number of parts in their unmodified “Sporting” configuration. They are considered imported because they have more than 10 imported parts in them. As such they are held to 922(r) compliance.

If you want to use high 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(r) does not apply. See bottom of this post for more 922(r) info and some grey areas.



Saiga Parts List

Here’s a quick overview of the parts count determined by the ATF definition letter listed at http://www.soupbowl.kalashnikov.guns.ru/page12.html. I have both Page 1 and Page 2 on my Downloads page. For the Saiga rifles, refer to the Galil/AK parts count. The Saiga Shotguns are directly referenced, however this has been updated with this newer 2011 ATF Definition Letter.

A Saiga Rifle has 14 parts, and a Saiga Shotgun has 15 parts, as imported.

(1) Receiver

(2) Barrels

(3) Barrel extensions

(4) Mounting blocks, trunnion

(5) Muzzle attachments

(6) Bolts

(7) Bolt carriers

(8) Operating rods (Shotgun Only)

(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



Examples

You have a Saiga-12 shotgun. (15 parts) You don't want to convert it, but you want to run some 10 round mags or that new drum. You will need 5 U.S. made parts to make it a U.S. firearm since running a magazine with more than 5 rounds violates 922(r). A U.S. made mag will be 3 parts, then a piston and a handguard will make it legal.

-or-

You have a Saiga-12 shotgun. (15 parts) You want to convert it to pistol grip configuration. You will need 6 U.S. made parts to make it a U.S. firearm since adding a pistol grip is adding a part from the list. Additionally if you add a flash hider, you will need 7 U.S. made parts. When doing the pg conversion you will have 5 parts right off with the fire control group (3), pistol grip and buttstock.

-or-

You have a Saiga-7.62x39 and want to use high capacity magazines. Since high capacity magazines are considered “unsporting”, and would be in violation of 922(r). Your rifle with mag has 14 parts. Use U.S. made mags and one additional U.S. made part like a gas piston and you are good to go.

-or-

You have an unconverted Saiga-410 (15 parts) and want to use the factory 10 round magazines. This is believed to be considered high-capacity in a shotgun and be in violation of 922(r). You will need to remove 5 imported parts and replace them with 5 U.S. made parts so you have no more than 10 imported ones total. A little more tricky because the only Saiga .410 countable parts currently on the market are handguards, pistons, hammers, disconnectors & some stocks. It's easiest to stick with U.S. made mags and get those 3 bonus parts.



Grey Areas

Sporting Purposes

While this was defined in the now-defunct AWB of 1994, the term "Sporting Purposes" is in actuality determined by the opinion of the Secretary of the Treasury. There is no clear ruling on what exactly that means so adding a bayonet lug or flash hider to the firearm may be considered "unsporting" and in violation of 922(r).

High Capacity Magazines

It has been argued what exactly high capacity magazine means. Generally it has been understood that the magazine limit for rifles is 10 rounds and shotguns is 5. Anymore than that and it’s considered “unsuitable for sporting purposes”.

Flash Hider/Muzzle Brakes/Compensators

Any type of Flash Hider, Brake or Compensator could be considered "Muzzle Attachments". They should be included in the parts count. However there has been some disagreement in the past as to whether adding a muzzle brake constitutes making the imported weapon “unsporting”.

Thread Protectors

A thread protector is not considered a "Muzzle Attachment" as it's not flagged out on the ATF's definition letter and most Saiga shotguns come with them.

Shotgun Chokes

It’s also arguable whether chokes are considered a "Muzzle Attachment" or not. Again, there is no clear definition I am aware of. To be on the safe side I’d consider a choke a countable part.

Shotgun Pistons/Operating Rods

The "Gas Piston" on a Saiga shotgun has now been defined as the grooved puck inside the gas block. The "Operating Rod" is now an additional countable part. The "Gas Piston" on the rifles and other AK’s is the part that is threaded into the bolt carrier. They do not have an "Operating Rod" and that is why the shotguns have one additional countable part.



922(r)

Section 922(r), of Title 18, U.S.C. prohibits assembly of certain semiautomatic rifles from imported parts. The implementing regulations in Title 27, Code of Federal Regulations (CFR) section 178.39(a), provide that 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.

For further information about 922(r), go to the ATF website http://www.atf.gov/ or http://uscode.house.gov/ and search for 18 U.S.C. § 922(r) and 27 CFR § 478.39 of the Gun Control Act (GCA) of 1968.



Additional Parts Count Resources

NOTE! - double check the parts count information in the links below against the recent Saiga-12 definition letter from 2011 before taking for granted.

For AK's - http://thegunwiki.com/Gunwiki/BuildAkVerifyCompliance

For Saiga's - http://thegunwiki.com/Gunwiki/BuildSaigaVerifyCompliance



In Summary

So you made it through all the gibberish above, I hope I have enlightened you a little about the legalities of modifying a Saiga. In short, convert the thing to a U.S. made firearm and do whatever you want to it. Just mind your parts count!

922(r) isn't such a bad thing, think of all the U.S. business you are helping to support, myself included. Also you are turning that ugly little antelope into a much more graceful looking thing of beauty! Remember, a factory configuration Saiga is an example of what the gun control fanatics would like to have all assault weapons look like. Do your job to support the American economy and convert them to U.S. made firearms!