I have been reading with interest all of the information being posted here regarding semi-auto MG42 builds and the fact that there has been no ATF classification letter published here, or anywhere else, for a semi-auto MG42.
From what I have been able to determine, BRP Corp. has the only ATF classification letter for a semi-auto MG42.
I have obtained a copy, from Brian at BRP, of their letter and it is posted below.
This letter is interesting in that it is not nearly as detailed as other ATF classification letters that I have seen, it doesnâ€™t have the ATFâ€™s normal preamble regarding machine guns, nor does it address 18 U.S.C. 922(r) which it should. Also, this is the first classification letter, that I have seen, which uses pictures to describe the weapon.
The 2nd letter, to Vector regarding their semi-automatic RPD, is in the format that the other letters I have seen follow. These letters normally follow this format:
A) Basic description of the submittal
B) Boilerplate machine gun definition preamble
C) The actual detailed description of the submitted sample
D) A discussion regarding US vs Foreign parts count - 27 C.F.R Part 478.39
E) Their â€œclassificationâ€ of the weapon.
- 1) The â€œnot a machine gun" statement
2) Itâ€™s a firearm as described in 18 U.S.C. 921(a)(3)
3) It complies with 18 U.S.C. 922(r)
G) Any other notes regarding the submission
H) Closing and signature
From BRP Corp.â€™s letter you can determine that:
The receiver appears to be all newly made with no de-milled sections used
The bolt has been modified
The â€œfiring mechanismâ€ has been modified
There is a â€œhardened blockâ€ in it somewhere
Thatâ€™s all that can be determined other than the ATFâ€™s statement on page 4 â€œAny modifications to the prototype or any deviation in the manner in which the receiver is constructed could change our classificationâ€
So, where does this leave us? Well, for one thing, we cannot point to the BRP letter as justification for our builds because BRPâ€™s submission was for a weapon constructed from all new receiver sections. The question of 18 U.S.C. 922(r) compliance is left open with no determination in BRPâ€™s letter.
Because we really do need a letter that classifies a weapon that is built the way most of us are building ours, I have started (see 3rd letter) by requesting a classification of a fire control group using US made FN-FAL hammer-trigger-sear and also for mounting the gripstick using a push pin for the front mounting. I have been informed (by phone) that Iâ€™ll have to submit a sample before I can get a classification. I really thought that the ATF would classify this change with only a letter but it appears that they, the ATF, will no longer make determinations from letters alone. Iâ€™ll post their reply when I receive it.
I hope this post will get us discussing how the â€œultimate SA MG42â€ should be made and one of us will take the time to submit a complete weapon for classification.
We need to come up with a configuration that all of us can live with, that will be in compliance, and be the easiest for us to build.
Here are some of my suggestions:
1) Receiver â€“ Built from de-milled receiver sections with no newly manufactured sections needed.
2) Bolt block â€“ There needs to be a substantial block welded in place and I can almost guarantee that the Â½ inch â€œstudâ€ that everyone seems to
be using will not pass ATFs muster.
3) Grip stick mounting â€“ I like the push pin mount as it looks stronger and overcomes the dust cover operating rod problem.
4) Fire control group â€“ I favor FN-FAL components in lieu of AR15 components.
5) Bolt â€“ The basic BRP design is fine but I think there is merit to having a 2-piece firing pin using the original firing pin.
Sorry for the long winded post but I hope this gets us thinking as a group regarding the direction we should all take to coming up with a really great design, getting it classified, and rest easy because we know we are doing the best we can to stay within the law.