A few months back, I wrote a post about "How not to have your life ruined by the ATFU", regarding short barreled rifles and shotguns, and AOWs.
Well, today I posted about the SKS I'm modifying, and a reader brought up another fine piece of ATFoolery, 922r. Specifically, he was concerned that I was non-compliant, and had assembled a rifle substantially identical to a non-sporting firearm which has been banned from importation. This is a felony.
For those of you who don't know what this is, basically a number of different "non-sporting" rifles, are banned from importation; including all variants of the SKS rifle.
Now, this wouldnt be a problem for guns already in the country, except for purpose of law, the ATF considers a rifle to have been "assembled" when certain parts are modified, changed, removed, remanufactured, or reassembled; and it is illegal to assemble, manufacture, re-manufacture or reassemble a foreign rifle that has been banned from importation.
It gets funnier however. For the purposes of law, a "foreign" rifle, is one that has with more than 10 of the following parts:
1) Frames, receivers, receiver castings, forgings or stampings
3) Barrel extensions
4) Mounting blocks (trunions)
5) Muzzle attachments
7) Bolt carriers
8) Operating rods
9) Gas pistons
10) Trigger housings
16) Pistol grips
17) Forearms, handguards
18) Magazine bodies
Now, not every gun has all of these parts. For example, of the 20 parts listed above, a Yugo 59/66 SKS has 17 of them (there is no pistol grip, no trunnion, and no barrel extension), some other SKS's only have 16 (no muzzle device).
I have the following US made parts
1 and 2. stock with a protruding pistol grip (counts as two parts)
3. gas piston
4. op rod
5. handguard (not currently installed)
6. magazine body
7. magazine follower
8. magazine floorplate
The muzzle device, bayonet attachment point, bayonet, and night sights have been removed, reducing my foreign parts count even further (only the grenade launcher counts there - the others are extraneous fr purposes of 922r).
Remember, it's only foreign parts which count. It doesn't matter how many US parts you have, only how many foreign parts.
My foreign made parts are as follows:
4. Bolt carrier
5. Trigger housing
10. Handguard (currently installed)
I believe this has me in compliance without a US made muzzle attachment, and without having yet installed the handguard; but I really do need to get around to putting the handguard on anyway.
As far as I know, with the US handguard, I'm absoltuely without any doubt compliant; because that would reduce my foreign parts count to 9.
Now, the problem is, some of the rules are open to interpretation, and the ATFU is well known for ambiguously interpreting rules against people. For example, the SKS has a double disconnector system, and some folks are concerned that the feddies may decide that they both count seperately as two parts, thus causing non compliance if you don't have the US made handguard installed.
Yes, this is all patently ridiculous, but that's the ATFU for you.
You can pick up compliance parts from vendors like Tapco, SKSman, and SKSparts for not very much money. Heck, I think all three of those vendors sell "compliance kits" which come with the 8 parts I listed above.