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Parts Count on Saiga Shotguns and Rifles


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I see the link to Wes's letter from the ATF about the Saiga shotgun no longer works.

 

http://www.soupbowl.....ru/page12.html

 

It seems odd to me that the ATF would issue an opinion letter that the Saiga shotgun trunnion is somehow unlike every other AK on the planet that they have repeatedly ruled was a separate part from the receiver and was inseparable from the sheet metal receiver if the trunnion was the serialized part given there is nothing in the US code that says shotgun trunnions are treated different than rifle trunnions. Is there another link to this opinion letter . I have been unable to find one on this site.

Can't get the link from the post to work, but Tromix had a post from Aug. 30, 2007: "I am guessing that the BATFE did not count the "trunion" because they consider that piece to be the actual "receiver" in the Saiga-12. It has the S/N on it and "receives" both the barrel and the bolt. That makes the part the receiver. They may also consider the front and rear trunion "assembled" in the channel to be the receiver, much like their ruling on the M60 receiver."

So does every other imported AK. In the case of stamped receiver AK's the serial number is on the trunnion and it is rivetted to the receiver that has the maker and importer info. Same deal. Trunnion receives the barrel and bolt. The ATF have consistently ruled in the case of AK's that if the trunnion is serialized it cannot be removed from the sheet metal receiver since that is the actual receiver. I know that because Ive sent them a letter and got a response back to that effect. They may have sent out an opinion letter contradicting that long standing opinion base but I wouldnt bet the farm they won't reverse that opinion the next time someone else sends them a letter. Legally opinion letters are really only good for the person who sent the letter in anyway. I'll have to contact Wes and see if he still has a copy of that opinion letter but to be honest without anything in 922r to corroborate it I don't think that opinion is worth the paper its written on. Next letter it will just get reversed.

Edited by wired
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Muzzle threads are not a part. As Dinzag has said in the tutorial.

Item number 4 is the BHO.   It is approximately 3mm thick, and if you are converting, will require you remove approximately the same amount of material from the replacement hammer axis shaft so th

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> I know that because Ive sent them a letter and got a response back to that effect.

 

Could you scan that and post it here? Or I'd be happy to send you postage or an SASE for a copy.

 

I've been hearing about this ATF decision for a long time, but nobody has had paper to back it up.

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> I know that because Ive sent them a letter and got a response back to that effect.

 

Could you scan that and post it here? Or I'd be happy to send you postage or an SASE for a copy.

 

I've been hearing about this ATF decision for a long time, but nobody has had paper to back it up.

ATF letters are only binding for the folks they're written to.

 

Posting them on public forums just causes confusion.

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  • 5 months later...

I've been searching for this specific info for awhile. I kept seeing people commenting on saiga 7.62x39 that after someone added a 20rd+ mag that it was no longer 922r compliant. So I finally understand why. Anyway I have a couple questions if others with more knowledge don't mind helping. I'm very interested in a Saiga 7.62x39 with a Dragunov Skeletonized buttstock/pistol grip which I understand drops the parts to 13?, maybe, since it's considered thumbhole. I would like to do some modifications like placing a 20rd possibly 30rd mag on it. And probably a rail for a scope. I'm wondering what parts are easily swappable with US made parts that I can swap out to keep it in compliance. I consider myself technically inclined but not necessarily mechanically inclined. By that I mean I'm skilled enough to disassemble/reassemble devices without too much difficulty but I'm not comfortable doing a lot of modifications with drills/dremels. Especially not considering a few hundred dollars to me is not chump change. I use drills daily for my professional life but that doesn't mean I want to risk ruining a brand new weapon with a "oops". Also what parts are normally already replaced on the Saiga to make it 922r compliant for the business to sale. I keep seeing mention that there are quality US made FCG replacements and granted I've not researched that a lot, yet, but from what I've seen those seem to be pretty straightforward to swap out. Although if it's already imported with a US FCG then swapping it would be moot since it wouldn't help me toward my 10 piece parts. Also what specifically is "unsporting"? Is it listed somewhere that "this" is unsporting and "this" is ok? I.E. is adding a rail and a scope unsporting? I would of course think not but if it's not spelled out in law then how am I to know some random ATF (or whomever enforces these policies) would not come up and cite me for what he believes is unsporting?

 

I apologize for carrying on but I want to build the gun as I see fit while still not having to be concerned that at some point I may be fined or the weapon be confiscated.

 

Thanks so much for any assistance!

 

Adam

 

P.S. Once I do get the gun and build it I look forward to being able to showing of the completed work like many others!

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I've been searching for this specific info for awhile. I kept seeing people commenting on saiga 7.62x39 that after someone added a 20rd+ mag that it was no longer 922r compliant. So I finally understand why. Anyway I have a couple questions if others with more knowledge don't mind helping. I'm very interested in a Saiga 7.62x39 with a Dragunov Skeletonized buttstock/pistol grip which I understand drops the parts to 13?, maybe, since it's considered thumbhole.

Unfortunately, it does not. The revenuers have decreed that if the pistol grip attaches directly to the receiver, it's a countable part.

 

Although if it's already imported with a US FCG then swapping it would be moot since it wouldn't help me toward my 10 piece parts.

Where did you hear this? No Saiga is imported with any US parts.

 

Also what specifically is "unsporting"? Is it listed somewhere that "this" is unsporting and "this" is ok? I.E. is adding a rail and a scope unsporting? I would of course think not but if it's not spelled out in law then how am I to know some random ATF (or whomever enforces these policies) would not come up and cite me for what he believes is unsporting?

There is no specific law. The only law gives the power to the Secretary of the Treasury.

 

The Secretary makes a list of "non-sporting" features (depending on administration, I suppose).

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I've been searching for this specific info for awhile. I kept seeing people commenting on saiga 7.62x39 that after someone added a 20rd+ mag that it was no longer 922r compliant. So I finally understand why. Anyway I have a couple questions if others with more knowledge don't mind helping. I'm very interested in a Saiga 7.62x39 with a Dragunov Skeletonized buttstock/pistol grip which I understand drops the parts to 13?, maybe, since it's considered thumbhole.

Unfortunately, it does not. The revenuers have decreed that if the pistol grip attaches directly to the receiver, it's a countable part..

 

 

Ok, this makes more sense now about the parts count. I believe I'm understanding that.

 

 

Although if it's already imported with a US FCG then swapping it would be moot since it wouldn't help me toward my 10 piece parts.

Where did you hear this? No Saiga is imported with any US parts.

 

 

If they are not imported with any US parts then how are gun stores able to sell them? Or is it just that they're considered sport rifles until the point you begin to modify them and that's when you have to meet the 10 piece US parts because they become assault rifles? I apologize for my ignorance.

 

Thanks for the help!

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Although if it's already imported with a US FCG then swapping it would be moot since it wouldn't help me toward my 10 piece parts.

Where did you hear this? No Saiga is imported with any US parts.

 

 

If they are not imported with any US parts then how are gun stores able to sell them? Or is it just that they're considered sport rifles until the point you begin to modify them and that's when you have to meet the 10 piece US parts because they become assault rifles? I apologize for my ignorance.

 

Thanks for the help!

They are sold as "sporting rifles", and as such require no US parts.

 

It's only when you add a feature that would disqualify the gun from importation that 922r kicks in.

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They are sold as "sporting rifles", and as such require no US parts.

 

It's only when you add a feature that would disqualify the gun from importation that 922r kicks in.

 

That makes complete sense then. I've read that the stock trigger with the dragunov skeletonized is pretty pitiful. If I were to only change that would that affect compliance?

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They are sold as "sporting rifles", and as such require no US parts.

 

It's only when you add a feature that would disqualify the gun from importation that 922r kicks in.

 

That makes complete sense then. I've read that the stock trigger with the dragunov skeletonized is pretty pitiful. If I were to only change that would that affect compliance?

You need to be more specific about "the dragunov skeletonized" stock you plan on using.

 

Will it be the Saiga-manufactured one or a US-made model?

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You need to be more specific about "the dragunov skeletonized" stock you plan on using.

 

Will it be the Saiga-manufactured one or a US-made model?

 

 

I'm assuming the Saiga-manufactured it comes equipped that way from the seller I plan on buying it from.

 

http://www.hyattguns...6.3-barrel.html

Yes, Dinzag sells trigger groups for factory Saigas, but you will be severely tested in their installation (it's nowhere as easy as a standard conversion). The main reason the triggers suck in the Saiga will still be there, too.

 

Better (IMHO) to just do a standard conversion.

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Yes, Dinzag sells trigger groups for factory Saigas, but you will be severely tested in their installation (it's nowhere as easy as a standard conversion). The main reason the triggers suck in the Saiga will still be there, too.

 

Better (IMHO) to just do a standard conversion.

 

 

I really, really appreciate your info! I'm beginning to lean that way as well as I've been reading basically all day about 922r and the conversion. You have no idea how much your info has helped me to understand 922r.

 

Thanks again.

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  • 3 months later...

Hi newish to replying to posts here and I have a few 922 questions

Saiga 12 W/threaded muzzle getting a 20 round mdarms drum.(feb18th 2009 production saiga 1 gas flute aggghhhhh)

I noticed in it's schematic only 2 parts from the list are on one of these.The magazine body and the followers.

No mention of floor plate.With the parts in the drum and a gas piston/puck would I have enough to get to the 10 parts for compliance or am I doing math wrong?

Be gentle

 

 

Well I found in the md20drum sticky,says its 3 compliance parts so I just need a US piston/puck perhaps?

Would using the US piston have any bearing on using the original Russian 5 rounder?

Edited by sufi pirate
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Im 99% sure my stock Arsenal s12 from K-var is good to go. I just want to make sure.

 

I have the K-var SGL12-02 with the Arsenal inc hand guard and threaded bbl.

 

To use the high cap mags I should already be good to go, mag = 3 parts and arsenal hand guard = 1, this brings the 14 parts down to 10 correct. I also have a us made choke threaded on the bbl. So in essence it only has 9 foreign parts

 

Am I legal.....I dont want to be a felon!

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  • 1 month later...
Would submiting an ATF form 1 for an SBS and sawing the barrel down to oh say 12'' make my S-12 "unsporting"?

Chopping the barrel would remove the "Muzzle attachments" part leaving me with 13 parts, toss the factory magizine (replace with a U.S. made one) and I'm at 10, right?

It would seem that I would have a "bad gun" if I took my 14 part factory S-12 and stuck a 10 round mag in it. If that is true, good thing I didn't buy any 10 round mags.

Some of these gun laws are like some kind of sick game.

I'd think any SBS is 'unsporting.' A stock Saiga S12 only has 13 countable parts, so if you use an AGP ten rounder you are still legal.

Yeah, once it's an NFA weapon, you no longer have to play the 922r game.

Bumping this as I am playing the waiting game to SBR a Draco. On a different thread, someone posted a letter from the BATFE stating you DID have to comply with 922r even with a NFA weapon. Anyone got better intel on this or a good contact at the BATFE to get to the bottom of this?

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Given AFTE, I'd send them a letter requesting the information, and park a notarized photocopy in a safe deposit box, original in your gun safe.

 

Reminds me, I need to send a letter to ATF to get a parts count for the PSL. I think that it's the same as any other AK rifle, but I want a something on ATF letterhead for safety. Shame that 3-gun competition is not a 'sporting purpose' as defined under the law, but I'll play the game. Replacement wood and trigger isn't too hard to do, but I could follow a discussion on general relativity better than I could follow all this expletive deleted 922R stuff!

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So My GF just picked up a Saiga12. She is going to convert it at some point in the near future when she has the money for the parts, but untill then she wants to be able to use 10 round mags. So since she has the threaded barrel model which is 14 parts, and she attatches a US made muzzle break (not flash hider) then it should still be in a sporting configuration correct? Which means that she should be able to use American made 10 round magazines, since that would be 4 US made parts for when its not in sporting configuration, and also be able to switch back to the Russian 5 rounder and it would immediately switch back to sporting? Correct?

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So My GF just picked up a Saiga12. She is going to convert it at some point in the near future when she has the money for the parts, but untill then she wants to be able to use 10 round mags. So since she has the threaded barrel model which is 14 parts, and she attatches a US made muzzle break (not flash hider) then it should still be in a sporting configuration correct? Which means that she should be able to use American made 10 round magazines, since that would be 4 US made parts for when its not in sporting configuration, and also be able to switch back to the Russian 5 rounder and it would immediately switch back to sporting? Correct?

 

That depends on whether the muzzle break would be viewed as a sporting or not...friggin subjective term.

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  • 5 weeks later...

Excuse my ignorance here.... I have had my Saiga 12 for a few years now, but this is my first time posting on the forum.

 

This is the list of US parts I replaced/added to my weapon when I got the gun in 2009:

- Pistol grip

- Buttstock

- Forearm/handguard

- Gas Piston/Puck

- Muzzle Attachment

 

In addition, I only really use my SureFire Mag.

 

 

According to http://jobson.us/922r/ and other checklists I've used - I am compliant with 922r.

 

But what about the Front & Rear Trunnion? Do they not exist at all on the Saiga 12, or is that open to interpretation by the ATF? If so, has that interpretation changed recently since they are trying to ban the importation of the Saiga 12s?

 

Thank you.

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  • 2 weeks later...

I apologize for my stupidy but something just doesn't make sense to me. I have a saiga 12s non threaded no BHO lock. According to what i have read on this forum i should have 13 parts. If i get a new american made magazine with 3 working parts im ok to convert it with a pistol grip which is what i really want to do. But what im trying to understand is that if the mag is not attached to the gun and i have it converted with a pistol grip, is it now illegal? This might be a simple question for some but i am just not understanding it. Any help will be greatly appreciated. Thank you.

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First of all, you need to have 10 or less foreign parts. Stop counting the American parts, and start counting the foreign parts. Adding a pistol grip does not subtract from foreign parts elsewhere on the gun.

 

Second, if there's no magazine in the gun, the "magazine parts" do not exist. You should never be able to make your gun non-compliant with 922r by removing a magazine.

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  • 5 weeks later...

Man, this is a little bit confusing.

 

Anyways I just got a S410 and I want it compliant if I use a 15 round Mag.

 

I was told that counts as 3 parts.

 

Now all I need now is (1) part right?

 

I hear multiple stories. Like I need 1 more part.

 

What is the easiest way to Legally use a high cap mag?

 

Is High Cap USA mag and USA Piston (4) parts enough?

 

 

Well Searching around I answered my own questions? Sorta stupid that I can be compliant with a 15 round mag and a piston, but if I put a grip on it I better not use a russian 5 shot mag. I guess add the most US parts on it so it is not an issue.

Edited by C-Par
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  • 1 month later...

I have just ordered a Iz109 saiga 12 with 19" barrel from carolina shooters supply and I live in NY. The posts were kinda old so I was wondering if I can mod my shotgun? If it still falls under the 922r compliance? and if so can I put a pistol grip and use 10 rd mags if I bring the 12ga under 10 foreign parts? If anyone know thx

Edited by ontargetguy
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  • 2 months later...

I didn't read this entire topic so forgive me if a letter similar to mine has been posted. I have often argued than the saiga shotgun with a threaded muzzle cap has 15 foreign parts. Many have said my position is incorrect. From what I understand, I was only incorrect that a saiga shot gun has 16 parts if it has a muzzle device (or maybe the saiga thread protector does not count as a muzzle device...) and now the saiga 12 has an operating rod. I present a copy of the letter I received from the firearms technology branch today.

 

LINK EMBEDDED, CLICK HERE

 

I have also attached a copy of the letter.

 

 

Updated wiki

 

922® Saiga 12 conversion wiki updated

 

http://gunwiki.net/Gunwiki/BuildSaigaShotgunVerifyCompliance

 

http://gunwiki.net/JustTheLaw/RefSaigaATF

batfe atf letter saiga 12 parts 10-13-2011.pdf

Edited by saigadd
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It would be really helpful if you could post a more legible copy of that letter. I for one, could not read it. I also believe, from what I was able to read, that you have the page is mixed up in order. Thanks

 

The letter includes, in order, the questions posed to the ATF, a few exhibits, the response to the question, and a copy of the envelope. As soon as you send me a scanner I'll use it and make a more legible copy.

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  • 4 months later...

I don't get how a mag is considered 3 parts. You're saying if I put a 30 round Mag and do the bullet guide mod, I'll be compliant? Why is everyone saying to do the forward trigger control move to knock-out 3 parts? I do understand that it looks more like a "real" AK that way and gives you more options for buttstocks and hand grips, but they have those for rearward Trigger set-ups.

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  • 1 month later...

I didn't read this entire topic so forgive me if a letter similar to mine has been posted. I have often argued than the saiga shotgun with a threaded muzzle cap has 15 foreign parts. Many have said my position is incorrect. From what I understand, I was only incorrect that a saiga shot gun has 16 parts if it has a muzzle device (or maybe the saiga thread protector does not count as a muzzle device...) and now the saiga 12 has an operating rod. I present a copy of the letter I received from the firearms technology branch today.

 

I read your letter to the BATF and their response and I notice that the list you provided for 922 parts on a factory Saiga 12 differed from what they said.

 

Your list:

  1. Muzzle Device
  2. Barrel
  3. Barrel shroud or Foreend
  4. Piston
  5. Bolt Carrier
  6. Bolt
  7. Hammer
  8. Trigger
  9. Disconnector
  10. Receiver
  11. Trunion
  12. Shoulder Stock
  13. Magazine Body
  14. Magazine Floorplate
  15. Magazine Follower

Their list: (reordered to match your list and removed items without asterisk)

  1. (Muzzle Attachment not on their list)
  2. Barrel
  3. Forearm/handguard
  4. Gas Piston
  5. Bolt Carrier
  6. Bolt
  7. Hammer
  8. Trigger
  9. Disconnector
  10. Frame or Receiver
  11. Mounting blocks (trunnions)
  12. Buttstock
  13. Magazine body
  14. Magazine Floorplate
  15. Magazine Follower
  16. Operating Rod

As for you questions, they didn't seem to specifically answer all of them, but seemed to let you infer the answers for some.

 

Q1: Is the piston puck considered the piston, or is the piston the part attached to the bolt carrier?

A1: Piston puck is the piston, rod attached to carrier is the operating rod.

 

--From what I had read prior to your letter, the Saiga 12 had never been considered to have an operating rod. The response to your letter seems that they have changed their position, possibly leading to a count of 16 parts that would fall under 922 rather than the 15 that were assumed before.

 

Q2: Does the Saiga 12 have a sear.

A2: Answer is an implied no as it does not have an asterisk next to it on their parts list.

 

Q3: Does the Saiga 12 have a trunion? Are the trunion and receiver counted as a single part or two parts for 922?

A3: Answer implied is that the Saiga 12 has a trunion and a receiver and that they are counted separately, based on the asterisked items on the parts list.

 

--From other posts I've seen in this thread (and possibly other threads) there was mention of the Saiga 12 possibly having more than one trunnion (front and rear?) The question that comes to mind from this is whether multiple trunnions would count as a single item for 922, or if multiple trunnions count as multiple parts...

 

Q4: Does a Saiga shotgun imported with a threaded muzzle attachment have 15 or 14 foreign parts for 922 purposes

A4: Implied answer is that the muzzle attachment on a Saiga shotgun does not count as a foreign part because it did not have an asterisk on the list they provided. Also implied is that the Saiga 12 has 15 parts as there are 15 asterisked items.

 

--So basically they answered some questions in a way that invalidated other parts of your questions and didn't expand on those parts that would need clarification. One other thing about the muzzle attachment issue that has always confused me is whether they consider the threads on the barrel to be the muzzle attachment, or the item that is threaded on to the barrel. From their answer to your question 4 it would seem to be implied that the threads themselves are not the attachment, and that the factory thread protector is also not an attachment. It is also possible that the person writing the response wasn't aware that there is a model of Saiga 12 that comes from the factory with a threaded barrel and thread protector, even though you specified it in your question.

 

 

What your letter and response has shown me is that everyone needs to write their own letter if they are particularly concerned about the issue, everyone needs to include many examples and cases that include what-if scenarios based on their answers to previous questions, and no two people will likely get the same response.

Edited by telero
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