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I have an IZ-109 and here are the parts I've put on it . Yes I checked all the other post but would like a yes or no & what I can or should do




Sgm tri rail

Red jacket muzzle break

Tapco t6 bolt on stock & pistol grip

Pro mag 10rd mag or 20rd drum or 20md-arms drum

Tlr-1s light

Forend grip ergo

Utg side rail mount

Sight mark reflex sight


What needs removed what can or can't I do as far as mag use goes and how many parts do drums count as ?


Thanks again

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Based on that list, a "yes" or "no" will not do. You need to understand this for your self. Your list shows me that you do not understand this.


It is not about adding parts it is about removing parts. Only listed parts count. This list makes it easy. Plug your parts in and check your own work. Rely on your own judgemnt, not mine.


Gunwiki: 922® Worksheet for Saiga Shotguns


Let's look at what you listed and see what I see:


Sgm tri rail - US made so it relaces 1 foreign part from the list : -1 foreign part
Red jacket muzzle break - grey territory. It sure ain't adding anything against you, so no worries.
Tapco t6 bolt on stock & pistol grip - US made so it relaces 1 foreign part (buttstock )from the list and does not add 1 pistol grip or remove 1 foreign. : - only 1 foreign part
Pro mag 10rd mag or 20rd drum or 20md-arms drum US made counts as 3 parts replaced: -3 foreign parts when used but a poor plan if you plan to keep any imported magazines such as your factory 5
Tlr-1s light - not on the list= don't care
Forend grip ergo - not on the list= don't care
Utg side rail mount - not on the list= don't care
Sight mark reflex sight - not on the list= don't care


15-2= 13 : legal only with US mags (-3=10). Not legal with your factory 5 (13).



You can add a hundred thousand US made parts and it won't matter. All that matters is taking off foreign parts that are on the list.


Suggestion: Get a trigger group, trigger guard w/ pg nut built in, and a S12 retaining plate, and use the pistol grip and stock from your T6 to do a proper restoration. It will cost you about $90 and you will have to tweak your pistol grip a little. It is very easy.


Reward: a gun that handles better feels lighter, a better feeling trigger, the ability to use any magazine legally, and be extra good on the parts count if they change the rules.

Edited by GunFun
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Wow ! There was question about the pistol grip being counted as a part the calculater I found counted the grip as a part but several people on the forum said no ? Things like that was the yes or no part the drum count for example. I got the take stuff off part thanks but they have to be replaced with american parts there was conflicting info on the grip so I posted up a list for opinions I'm not going to mess with my S-12 to much it has ran perfect from day one . I just wanted to double check that drums and 10rd mags were ok to use and get any other opinions that would be out there make conversation isn't that what forums are for lol

I guess thanks for the response

Edited by Guns4Gods
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That calculator works from what I can tell, but I can see where it would be a bit confusing for someone trying to understand 922r since it counts both US and imported parts. Like GunFun said, the only thing that matters under 922r to the people who enforce it is how many imported parts are in your non-sportorized Saiga.


All said, there is a lot of territory left open for interpretation under 922r (including what exactly makes a firearm non-sporting), which can (and does) vary day-to-day, person-to-person, etc. With the mood and public attention the way it is right now, the advice you are going to get from anyone here is to put in a little extra effort and cover your six. If you don't want to do that and rely on your magazines to keep you compliant under 922r, that's totally your call. But keep in mind that while the delivery of the message may vary, most of us have been around the block a time or two and are just trying to keep you in the good graces of Big Brother under the worst of circumstances. wink.png


And FWIW, Saigas operate better with a proper US FCG/PG conversion since that's how they were designed to work in the first place. Moving the trigger back and adding linkage to the FCG was done solely to comply with US import laws.

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Thanks for responding FLT. I wasn't sure about the pistol grip as -1 and how many parts the mags counted as plus the list I used counted the muzzle break as -1 . I just wanted a second opinion and make small talk as I'm a new member . Instead I get told I don't understand the law in a kinda rude way . I understood the law which is why I wanted to double check and get advice on small things I could do to meet the requirements maybe gas puck v- plug you get the point :-) at some point I do want to convert my S12 but I'm very hard on my weapons for me there not just for looks so until I find someone that will help me do this I would rather have a reliable gun instead of being another poster saying something wrong after I converted my gun thanks again FTL

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As for rudeness- No. I was clear, not rude. I didn't insult you. I didn't call you stupid. (There are plenty of people on any forum who live to call new guys stupid) You are new, and what you wrote showed that you were confused. Many people are about this subject. I just made it clear that your thinking is wrong and can get you into trouble. I then tried to make it clear what your thinking should be. I even gave you the correct up to-date source. So call me rude for trying to help you out. I spoon fed you the current info and you chose to look up out of date info. I doubt any answer would have made you happy other than a "yes", which would have been setting you up for trouble.



The check list I linked above stays more current. It is updated to reflect that the "bolt carrier extention" (part that would be a piston on a standard AK) is now considered by the ATF to be an operating rod for a total starting point of 15 parts. This was from a few opinion letters early 2012. Those same letters are the ones that clarified that current studies do not consider the pistol grip to automatically trigger 922r. (prior to those 2012 import studies, the ATF did state in every opinion letter and import study that presence of a pistol grip would automatically trigger 922r.) Due to the contradictory statements from the government, most would consider it unwise to risk having a pistol grip on a gun that exceeds parts count with some of the magazines they own.


Once you get any features on the naughty list you have to play the 922r game. A pistol grip no longer necessarily puts you on the naughty category on its own, but it is still on the list for parts counts. Magazines bigger than 5 mean that whatever other features (i.e. pistol grip) you have don't matter, you are playing the 922r game! A foreign pistol grip would count against you on your count, and a US made one would not.


Some people find it helpful to think of it in grade school math terms: Johnny has a basket that was imported with 15 red Russian apples. If Johnny puts 5 green American apples into the basket, how many red foreign apples are in the basket? Answer 15. How many green apples does Johnny need to add to the basket so that he will have 10 red apples?... The basket also contains pears and grapes. If Johnny takes out 10 grapes, how many red apples are in the basket?...


You really need to stop thinking about how many american parts (green apples) you are putting on, and start thinking of how many imported parts (red apples) you are taking off.


You can take this as an insult or you can choose to look at it as an attempt to help you understand. I don't really have the energy to waste on insulting strangers. I do try to make the time to help them. You say you understand the law, but your last statements about pistol grips demonstrates that you really don't yet.


Putting on an American pistol grip is not taking off any foreign parts. There wasn't a foreign one there in the first place.

Edited by GunFun
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I understood X amount of parts needed replace as to which I was getting different answers so I thought I would dbl check I also posted the list of parts that I already put on the gun to describe the gun just for small talk and for any opinions of things that could be done such as a gas puck for example then you chime in and tell me I don't understand ? Your in every post on here mr 3000 posts some you don't read threw very well or make bad jokes or just make a comment to get your post count up ! No matter I will not return to this forum again . Thanks to the forum for the great info and ideas I've picked up while I was here but the smart ass post above is the exact reason I put ( kinda rude ) I won't be back thanks again to the forum for all the good info and picks . GunFun you can stick the green apples up your ass !

Edited by Guns4Gods
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Glad it helped someone. Welcome mr. Stang.


3000 posts... Well, I've spent too much time on line then. I'll spend #3000 welcoming someone who came in on #1 expressing gratitude.

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  • 2 weeks later...

The "Starting point" of parts counts depends on the starting condition of the gun. Saiga's have no pistol grip., so they are not "counted" in the original configuration. So the typical starting count is 14 foreign parts for Saiga rifles ( as an example), requiring 4 or more "listed" parts to be replaced by US made parts. If you decide to change to AK-style, that now will have a stand-alone pistol grip, you need to use a count-start of 15 pieces, because you've added a feature you didn't have originally. This "new" feature better be a US-made part ! Your goal is to have 10 or less foreign made parts after the conversion.


Under the newest SAFE act in NYS, on top of the 922r parts-count business....do realize that ANY muzzle brake OR Flash hider is now illegal. Prior to this, FH were illegal and muzzle brakes were not, but there were separate issues of whether or not your gun had a threaded barrel which complicates matters. Prior to SAFE law, people got around the threaded barrel aspect by "permanently" affixing the MB ( not FH, as these were illegal even then), like high-temp silver solder.....which a certain, documented BATF ruling once said was OK , and is being used as a reference guide now ( when the law was a Federal law).

Edited by IPSC45
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  • 9 months later...

p.s. A few months back, Jobson? posted that he wanted to put his list into public control, because the site upkeep was getting high.. I don't remember his member name here, but I put him in touch with the more up to date info. I think he updated it at the time, but I don't think he intends to keep updating it. I appreciate his service in putting that up initially, but that underscores the fact that we all need to be sure of the source and currency of any thing we use to come to a legal conclusion. If you think you are running into grey territory, either hire a lawyer to sort it out for you, or spend a couple more dollars and put yourself a couple parts to the side of safe. Either of those is way cheaper than a prosecution.



Edit 1- I checked the Jobson link. It looks like he still keeps it up, but he stripped it down to the pure statutory checklist without any guidance on what parts have been determined present for each category in any specific platform. (probably a smart move for him) Gunwiki: 922® Worksheet for Saiga Shotguns is still a better resource for saiga based weapons.

Edited by GunFun
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One of the things I learned in researching converting my S12 is you have to take stuff off to be legal with mags larger than the five rounder that came with your gun. As I converted mine I removed the russian fire control group, the russian butt stock, the russian bolt hold open device, and the russian piston / puck, the russian forearm, and the russian trigger guard. I added an American made Tromix fire control group, an American made Carolina Shooters billet trigger guard, an American made modified bolt hold open device, an American made Advanced Tactical butt stock, an American made Hogue pistol grip and a JT Engineering muzzle brake.  In the end I have six russian parts that count remaining and should be legal......

Edited by Inspector 12
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Inspector- Three of the parts you list are not factored by the BATF for this firearm. The BHO is not on the statutory list. The trigger guard is not on the statutory list. Replacing either has nothing to do with 922r.


BATF has given letters to several, notably including Tony Rumore to the effect that they do not consider brakes or chokes on shotguns to be "muzzle devices' within the meaning of the law. They could change their mind about the second one. 


Pistol grip S12 starts at 15 (16 if the pistol grip is imported)


Stock -1 = 14

FCG -3 = 11

puck(which is the "piston") -1 = 10 Yay

forend -1 =9

{if by piston you mean that you also replaced the part that is a piston on an AK (checklist "operating rod" per BATF) - 1 =8}




9 parts even with foreign mag. 6 with US mag.

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"No matter I will not return to this forum again . Thanks to the forum for the great info and ideas I've picked up while I was here but the smart ass post above is the exact reason I put ( kinda rude ) I won't be back thanks again to the forum for all the good info and picks . GunFun you can stick the green apples up your ass !"


Grow up kid! You asked for our opinions and when who is knowledgeable in this subject answers, you respond very "rudely". You will need to put your daddy's gun back in the safe and go to your mommy's purse and grab her tampon's and shove them up your a$$! Grow some skin and when someone is trying to help you, listen to them, or quit asking.

Edited by Sport Rescue
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