Parts Count

[hcpookie]

Does anyone have a list of parts that are counted by the ATF for compliance purposes?

[panaceabeachbum]

I am curious on this one also, wouldnt a semi 42 assembled from imported kit still require a certain number of us made parts to be compliant? I guess since you are making the reciever, modifyig the bolt and modifying the stick grip they would count as 3.

[drooling idiot]

i think this breaks down as ...
you can't build a gun from foreign parts thats on the restricted from import list , SA42's only exist in the U.S. (to my knowledge) so they have never been evaluated for import into the U.S. and not being evaluated they aren't on the prohibited list.
In a nutshell , parts count isn't an issue , I think.

[Intruder196]

I always heard that the parts count was for guns with certain features, such as pistol grip, the ability to use detachable hi-cap mags, bayonet lug, flashhider, threaded muzzle.

I think the parts count isnt an issue with the SA42 because belts arent considered as hi-cap mags. I might be mistaken though.

[MauserMatt]

I think asking BRP would probably be the best way to find out... Or someone that has a BRP gun..

[gunslingerdoc]

The rule relates to not being able to assemble a "non importable" gun; ie. non sporting. Since "assault rifles" is no longer a defined legal/federal term with the sunset of the ban, we're back to non-sporting = non importable. You can make it here, provided its a US made gun. just not assemble a non-importable rifle/pistol from all foreign parts to skirt the import restriction. In order to be a US made gun it cant have more than 10 listed foreign parts. This is how we get to the 'parts count' issue when you want to build your Fal, AK, of G3 clone.

"non importable" or "non sporting" gets harder to define since its a largely arbitrary govt determination. Im pretty sure that the 3-letter folks would rule a SA mg-42 non importable since they probably wouldnt find it 'sporting'.

So what parts are foreign that count on the 'list' in a SA mg42?

barrel, bolt, bolt carrier, stock, grip, muzzle brake/flash hider, charging handle = 7 parts.

Since the receiver is 'scrap' I think we can call it US made.
even if we use a fal FCG - hammer, trigger, and sear (rest of the springs and crap dont count) we're only at 10 parts. .gov doesnt list 'belts" an official 'part' in their list, so we're Ok there.

Since the rule is "more than 10 foreign parts", 10 is legit.

THis is my read, but Im not a lawyer.

[panaceabeachbum]

Thanks Doc, That sounds reasonable, i have tryed at length to ask Brian at BRP these questions but since this is his livelyhood he aint'a sharin. Considering the amount of mods to the bolt and stick grip would it be safe to say they are now american made?

[gunslingerdoc]

I would say the bolt and grip stick remain 'foreign made parts' even after mods. - look at it like taking a single stack AK-47 clone and milling the mag well to take regular Ak mags, then riveting in a cartridge stop. The receiver has been changed in the US. It can easily go back to its imported form, but its still a 'foreign' made receiver. Its a modification, not an actual production.

Since both the grip frame and bolt are functional when imported, I dont think modifying them is viewed the same as manufacturing them from scrap or raw materials. Stupid I know but I dont make the rules, but we have to follow them....

We get away with welding up the receivers because we are not converting a machine gun to SA, we are making a gun from 'scrap'. Remember if it wasnt considered 'scrap' then it would still have to be an MG and only importable for govt. or LE. So when someone quotes the , "once an MG always and MG" line and says your going to be Bubba's new love toy, you can now explain to them that you are making a receiver, not converting or modifying one.

[panaceabeachbum]

is the general assumption everyones working under that since the mg42sa is not on the import ban list that its not required to meet the same parts count criterea as say an ak/fal build? Just want to make sure before I get started on anything

[gunslingerdoc]

Since there are no longer "assault rifles" as defined by federal statue..... 'The list' stuff is out the door, IMO. Its more a clarity issue in that they name certain guns as non-sporting therefore non importable. Now we're stuck with the rather arbitary definition of "sporting purposes". THis means they could decide tomorrow that your beretta SA 12 gauge is non-sporting and ban importation. There is a system whereby firearms get points toward being sporting - things like adjustable sights, finger rests (target type grips) help a weapon improve its "sporting" score. This is the reason that makarovs had funky grips with finger rests on them and others had adjustable sights for example.

I know Im being picky here, but its important we all use the correct terms and read law/rulings and legal opinions so we're all talking about the same stuff.

Realize Im not a lawyer. I can read and I ask lots of questions of my Federal Prosecuter relative but Im not going to be defending you in court.

From a more real standpoint, Im a doctor that likes guns. Guns are not my living. They are a HOBBY. Im not going to do ANYTHING that Im not personally sure is legal. Why would I want to risk, fines, jail time, lossing all my guns and pissing away years of education that Im still paying off? Im not!

So while Im totally convinced that Im doing nothing illegal by building a SA MG-42, I encourage EVERYONE to be sure for themselves. If youre not, dont do it.

[panaceabeachbum]

Read the atf's take on the 42 sa over at weaponeer, As best I understand the 42sa is a shoulder fired weapon, not a rifle or assault rifle, so the 922r (which is still in effect) US parts count does not apply, as doc mentions above.