Parts Count on Saiga Shotguns and Rifles
In this document I will attempt to express my understanding of the current laws and how they apply to the Saiga firearms. If you have questions & concerns or disagree with what I've put together, we can modify. The scope of this is to have a post to link members to if they have parts count questions. I realize there are several posts on this, but most do not specifically apply to both rifles and shotguns. Maybe this can be stickied somewhere handy.
Before doing anything, check with your local and state laws as you may have tighter regulations than what the ATF has laid out for us.
The Saigas have a certain number of parts in their unmodified “Sporting” configuration. They are considered imported because they have more than 10 imported parts in them. As such they are held to 922 ® compliance.
If you want to use high capacity magazines, convert the weapon to pistol grip configuration or use a flash hider, it will then be considered unsporting. You will need to swap out parts so that you have no more than 10 imported parts in it. It will then be considered a US made firearm and 922® does not apply. See bottom of this post for more 922® info and some grey areas.
Parts List
Here’s a quick overview of the parts count determined by the ATF definition letter listed at
http://www.soupbowl.kalashnikov.guns.ru/page12.html. For the Saiga rifles, refer to the Galil/AK parts count. The Saiga Shotguns are directly referenced.
A Saiga Rifle in factory configuration has
14 parts.
A Saiga shotgun threaded for chokes has
14 parts.
A Saiga shotgun not threaded for chokes has
13 parts.
(parts on a factory config saiga are in
bold)
(1) Receiver
(2) Barrels
(3) Barrel extensions
(4) Mounting blocks, trunnion (rifles only)
(5) Muzzle attachments (shotguns w/ threaded barrels only)
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors
(15) Buttstock
(16) Pistol grips
(17) Forearms, handguards
(18) Magazine bodies
(19) Followers
(20) Floorplates
Examples:
You have a Saiga-12 with factory threaded barrel. (14 parts) You want to convert it to pistol grip configuration. You will need 5 U.S. made parts to make it a U.S. firearm since adding a pistol grip is adding a part from the list.
-or-
You have a Saiga-7.62x39 and want to use high capacity magazines. Since high capacity magazines are considered “unsporting”, and would be in violation of 922®. Your rifle with mag has 14 parts. Use U.S. made mags and one additional U.S. made part like a gas piston and you are good to go.
-or-
You have a Saiga-410 and want to use the factory 10 round magazines. This is believed to be considered high-capacity in a shotgun and be in violation of 922®. You will need to remove imported parts and replace them with U.S. made parts so you have no more than 10 imported ones total.
Grey Areas
Sporting Purposes…
While this was defined in the now-defunct AWB of 1994, the term "Sporting Purposes" is in actuality determined by the opinion of the Secretary of the Treasury. There is no clear ruling on what exactly that means so adding a bayonet lug or flash hider to the firearm may be considered "unsporting" and in violation of 922®.
High Capacity Magazines…
It has been argued what exactly high capacity magazine means. Generally it has been understood that the magazine limit for rifles is 10 rounds and shotguns is 5. Anymore than that and it’s considered “unsuitable for sporting purposes”. Problem is there are no clear definitions stating that exactly.
Flash Hider/Muzzle Brakes/Compensators…
Any type of FH, Brake, Comp or choke are considered muzzle devices. They are included in the parts count. However there has been some disagreement in the past as to whether adding a muzzle brake constitutes making the imported weapon “unsporting”.
Shotgun Chokes…
It’s also arguable whether chokes are considered a part or not and the threading itself is not considered a part, but to be on the safe side I’d consider a choke or thread protector a muzzle device.
Shotgun Pistons…
It’s been the general understanding that the grooved plug in the gas block on the shotguns is considered the piston and the rod on the bolt carrier is either and operating rod or carrier extension. The gas piston on the rifles and other AK’s is the part that is threaded into the bolt carrier.
Parts count difference between the rifles and shotguns…
The main difference between the rifle and shotguns parts counts is the shotguns do not have #(4) Mounting blocks, trunnion. I don’t really understand that part because to be they look to have the same general construction, but that is how the definitions are listed by the ATF themselves.
922 ® in short…
Section 922®, of Title 18, U.S.C. prohibits assembly of certain semiautomatic rifles from imported parts. The implementing regulations in Title 27, Code of Federal Regulations (CFR) section 178.39(a), provide that no person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph © of this section if the assembled firearm is prohibited from importation under section 925(d) (3) as not being particularly suitable for or readily adaptable to sporting purposes.
For further information about 922®, go to the
ATF Website or
http://uscode.house.gov/ and search for 18 U.S.C. § 922® and 27 CFR § 478.39 of the Gun Control Act (GCA) of 1968.
In Summary
So you made it through all the gibberish above, I hope I have enlightened you a little about the legalities of modifying a Saiga. In short, convert the thing to a U.S. made firearm and do whatever you want to it. Just mind your parts count!
922® isn't such a bad thing, think of all the U.S. business you are helping to support. Also you are turning that ugly little antelope into a much more graceful looking thing of beauty! Remember, a factory configuration Saiga is an example of what the gun control fanatics would like to have all assault weapons look like. Do your job to support the American economy and convert them to U.S. made firearms!
