In September 2014, the Bureau of Alcohol, Tobacco, Firearms, and Explosives revised Publication 5300.4, section IV.B.8.c, on the “Assembly of Nonsporting Semiautomatic Rifles and Shotguns from Imported Parts.”
Part of section 922(r) of Title 18 U.S. Code reads, “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 purpose.”
Under this revision, it is illegal to assemble a nonsporting semiautomatic shotgun or rifle, or one that is identical to a nonsporting semiautomatic shotgun or rifle that is specifically forbidden under the Gun Control Act of 1968 – using a certain number of imported parts.
Specifically, it is expressly illegal to assemble these firearms using more than 10 imported 922(r) parts. The complete list of 922r parts is as follows:
- Frames, receivers, receiver castings, forgings, or stampings
- Barrels
- Barrel extensions
- Mounting blocks (trunnions)
- Muzzle attachments
- Bolts
- Bolt carriers
- Operating rods
- Gas pistons
- Trigger housings
- Triggers
- Hammers
- Sears
- Disconnectors
- Butt stocks
- Pistol grips
- Forearms, hand guards
- Magazine bodies
- Followers
- Floor plates
If a nonsporting semiautomatic shotgun or rifle were assembled using more than 10 of the above 922r parts, it would be illegal under 922(r) of Title 18, U.S.C.
922r Parts and Compliance
For an assembled nonsporting semiautomatic shotgun or rifle to be legal and 922(r) compliant, that platform must be made with fewer than 10 imported parts specified on the list in the revision to the code, as displayed above.
For those that are still interested in creating semiautomatic clones or lookalikes of regulated firearms from imported kits, it is vital that fewer than 10 specified imported parts be included in the build.
The workaround for most hobbyists is to use American-made parts in lieu of imported parts. While 922(r) allows for 10 or fewer imported parts to be used in the assembly of nonsporting semiautomatic rifles and shotguns, the way to create a compliant version is to use all American-made parts, or a combination of American and foreign-made parts, with 10 or fewer from the list above being foreign-made.
This is different for each platform. For instance, if a nonsporting semiautomatic shotgun or rifle included 13 of those parts specified in the revision to the code, only 10 of them could be imported; 3 would need to be American-made.
Of course, if you use only American-made parts, or buy legal American-made variants, this should not be a concern.
Section 922r and Pistols
It is important to note that Section 922(r) applies only to nonsporting semiautomatic rifles and shotguns, and not to pistols.
However, it is also important to be aware that though some of Zenith’s imported roller-delayed firearms are imported as pistols, if they were assembled into rifles, they would contain more than the 10 allowed 922(r) parts, depending on the configuration, making them non-922(r) compliant.
It is also impossible to compile a complete list of 922(r) compliant firearms because the number of 922(r) parts the platform contains would depend both on the model in question and on any modifications made by the person performing the assembly.
Instead, it is vital to be aware of all of the components of the platform in question and to ensure you never assemble the platform unless it contains less than 10 of the above-listed parts – the remainder must be American-made.
Section 922(r) and Magazines
A special note on magazines: Section 922(r) considers magazines to be not one 922(r) part but three, being the magazine body, follower, and floor plate.
It is vital to be aware of this because if you have an assembled non-sporting semiautomatic rifle or shotgun that includes 9 922(r) parts, and insert a foreign-made magazine, you suddenly have 12 922(r) parts, and that platform would become illegal under revision 922(r).
It is important to be aware of the number of existing 922(r) parts in your platform and never exceed them. You can also use American-made magazines to be safe.
Zenith Firearms and Section 922(r)
Zenith Firearms cannot, does not, and will not sell parts knowing that the end user intends to use them to complete or modify an assembled platform in violation of Section 922(r) of Title 18 U.S.C.
However, if you have any questions about our platforms or about the number of imported and American-made parts they contain so you can be certain you are in compliance with 922(r), feel free to contact us at 434-202-7790 or at [email protected]. We aim to offer a high level of customer service and would be happy to at least try to offer you answers to any questions you have.
Disclaimer: Seek Your Own Legal Counsel
Do not take anything contained in this post for binding legal counsel. If you have any legal questions whatsoever, direct them to an experienced firearms lawyer in your area with demonstrated abilities in handling cases pertinent to ATF regulations and to federal and state firearms law.
Is it ATF compliant to use a 2 point strap on a semiautomatic pistol. Might this be viewed as a form of support limited to long guns?
Yes it is.