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ATF Response to Legality of Full Length Mag Tube on Benelli M4


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Just got my letter back today. The two gas pistons on the M4 only count as one imported part.

 

The pertinent part of the letter states, "where a single item contains a combination of multiple "parts," it still shall only count as one item. The A.R.G.O. counts as one part."

 

Sound familiar? The one piece non-telescoping pistol grip buttstock is a single item which contains a combination of multiple "parts," which is why it only counts as one item.

 

ATF responses are consistent. 13 part count for the M4 with the standard field buttstock/ one piece non-telescoping pistol grip buttstock. 14 part count for the M4 with a separate pistol grip and a separate buttstock.

 

Upon reading this logic, I consider the Benelli M4S90 firearm to be a single item (It has a single serial # and is identified as such. A single item.) containing a combination of multiple parts. Screw your 922r.

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Upon reading this logic, I consider the Benelli M4S90 firearm to be a single item (It has a single serial # and is identified as such. A single item.) containing a combination of multiple parts. Screw your 922r.

 

I said the pertinent part of the letter Jr.. They clearly note the M4 shotgun is not a single item. I was thinking why put that in there only an idiot would argue that.

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I said the pertinent part of the letter Jr.. They clearly note the M4 shotgun is not a single item. I was thinking why put that in there only an idiot would argue that.

 

Nothing about that letter is pertinent, imho. All of my M4's were built by someone else, and 922r is only about assy., not possession. So I'm not worried about it. :)

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Hey ShadowShooter and Hookster,

 

Would you guys mind posting your response letters also? It would probably be good for everyone to see the consistency in the responses from the ATF as well as any differences in the answers that they may have given.

 

Pleasure.. Thanks for the SOCOM 16 post. I shot that hog the other day. That thing is sick!!!
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If you guys would post your letters, that would be great. What address are you sending your letters to? Is it dependent on your location in the US? I assume that you are sending a picture of your M4. I am starting my letter this weekend. I will post mine once received! Thanks!

 

Best, John

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If you guys would post your letters, that would be great. What address are you sending your letters to? Is it dependent on your location in the US? I assume that you are sending a picture of your M4. I am starting my letter this weekend. I will post mine once received! Thanks!

 

Best, John

 

John,

 

Here is the address you want to send it to. Don't bother asking or emailing your local ATF branch to write you a letter, because they won't even know what 922 r is. Plus the Firearms technology branch is where they make the determination of the number of parts.

 

Attn: Firearms Technology Chief

ATF Firearms Technology Branch

244 Needy Road

Martinsburg, West Virginia 25401-9431

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Hey ShadowShooter and Hookster,

 

Would you guys mind posting your response letters also? It would probably be good for everyone to see the consistency in the responses from the ATF as well as any differences in the answers that they may have given.

 

No problem MeanGreen, I'll get a copy posted soon.

 

Hookster :)

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Hey ShadowShooter and Hookster,

 

Would you guys mind posting your response letters also? It would probably be good for everyone to see the consistency in the responses from the ATF as well as any differences in the answers that they may have given.

 

Sure as soon as I get my scanner up and running again...

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  • 3 months later...
Just got my letter back today. The two gas pistons on the M4 only count as one imported part.

 

The pertinent part of the letter states, "where a single item contains a combination of multiple "parts," it still shall only count as one item. The A.R.G.O. counts as one part."

 

Sound familiar? The one piece non-telescoping pistol grip buttstock is a single item which contains a combination of multiple "parts," which is why it only counts as one item.

 

ATF responses are consistent. 13 part count for the M4 with the standard field buttstock/ one piece non-telescoping pistol grip buttstock. 14 part count for the M4 with a separate pistol grip and a separate buttstock.

 

Wait...aren't the non-telescoping & telescoping versions the EXACT SAME PARTS? The only difference is the milled recoil tube, which is part of the receiver! How the **** does it count both ways?

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Wait...aren't the non-telescoping & telescoping versions the EXACT SAME PARTS? The only difference is the milled recoil tube, which is part of the receiver! How the **** does it count both ways?

 

It doesn't. 14 part count for the M4 with a separate pistol grip and a separate buttstock, irrespective of whether it is collapsible or not.

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This is the best summary I can give you. A list of the 13 parts the ATF states are in the M4.

 

1) Receiver

2) Barrel

3) Bolt

4) Bolt Carrier

5) Gas Piston

6) Trigger Housing

7) Trigger

8) Hammer

9) Disconnector

10) Buttstocks

11) Forearm

12) Magazine body

13) Followers

 

If you want to add a full length mag tube then you'll have to replace 2 other parts. Currently there are US made followers and forearms on the market. Mesa Tactical is making a US made pistol grip buttstock to be released in April, so that will make three. I sent a follow up letter to the ATF regarding the Mesa pistol grip stock and it will count as one US made part since it is a fixed non-telescoping pistol grip buttstock.

 

As long as you swap out 2 other parts with your US made full lenth mag tube you are safe. Only have 10 imported parts in total.

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This is the best summary I can give you. A list of the 13 parts the ATF states are in the M4.

 

1) Receiver

2) Barrel

3) Bolt

4) Bolt Carrier

5) Gas Piston

6) Trigger Housing

7) Trigger

8) Hammer

9) Disconnector

10) Buttstocks

11) Forearm

12) Magazine body

13) Followers

 

If you want to add a full length mag tube then you'll have to replace 2 other parts. Currently there are US made followers and forearms on the market. Mesa Tactical is making a US made pistol grip buttstock to be released in April, so that will make three. I sent a follow up letter to the ATF regarding the Mesa pistol grip stock and it will count as one US made part since it is a fixed non-telescoping pistol grip buttstock.

 

As long as you swap out 2 other parts with your US made full lenth mag tube you are safe. Only have 10 imported parts in total.

 

Thank you Very Much.

 

Seems A bit out of touch with reality, but that's our government.

 

Remove 3 parts from the gun exchange them with USA produced parts and it's legal to carry extra rounds :confused:

 

I really appreciate all your hard work on researching this matter.

 

Let's See, I replaced the Mag tube with Carrier Comp, the Bolt handle with DMW, just need to replace one more? Anybody make a cool USA made Trigger?

 

NEWGUNNER.

Edited by NEWGUNNER
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Thank you Very Much.

 

Seems A bit out of touch with reality, but that's our government.

 

Remove 3 parts from the gun exchange them with USA produced parts and it's legal to carry extra rounds :confused:

 

I really appreciate all your hard work on researching this matter.

 

Let's See, I replaced the Mag tube with Carrier Comp, the Bolt handle with DMW, just need to replace one more? Anybody make a cool USA made Trigger?

 

NEWGUNNER.

 

Hi NEWGUNNER,

 

The DMW bolt handle does nothing for you as far as reducing your count of imported parts since bolt handle is not on the list of 13 parts. Keep your Carriercomp, replace your Fab forearm with a KZ or Surefire and install a Brownell's follower and you'll be good to go. OR you could wait a month or two and get a Mesa stock and the follower and keep your Fab forearm if you like it

 

Later,

 

Hookster :)

Edited by Hookster
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Hi NEWGUNNER,

 

The DMW bolt handle does nothing for you as far as reducing your count of imported parts since bolt handle is not on the list of 13 parts. Keep your Carriercomp, replace your Fab forearm with a KZ or Surefire and install a Brownell's follower and you'll be good to go. OR you could wait a month or two and get a Mesa stock and the follower and keep your Fab forearm if you like it

 

Later,

 

Hookster :)

 

Thank you for the clearification, I thought Item number 3 was the bolt handle.

 

I just ordered a DMW follower, and that Surefire forearm sure looks tempting.

 

I was just a little concerned with the extra weight, of aluminum VS the Plastic when I made the decision to go with the FAB, this was all before I read this post on 922r.

Edited by NEWGUNNER
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Welcome back MG ! It's been a while!

 

Later,

 

H:):)kster

 

Thanks Hookster, I have been completely immersed in updating this house we just bought. So I haven't even looked at my Benelli in a couple of months. We'll have to try and hook up for a surf next time we're down your way.

 

MeanGreen

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Thanks Hookster, I have been completely immersed in updating this house we just bought. So I haven't even looked at my Benelli in a couple of months. We'll have to try and hook up for a surf next time we're down your way.

 

MeanGreen

 

Sounds Good MG!

 

I missed the last Cow Palace gun show but I'll be hitting the next one.

I'm heading up for some snowboarding tomorrow!

 

:)

Edited by Hookster
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  • 3 months later...
Guest cleefurd
Yes...but is the follower stamped "Made in USA"? :confused:

 

If a component distinguishes itself from the import item by being impossibly similar, and has documentation supporting indiginous origin such as packaging and receipts trace-able to a bona-fide domestic manufacturer that does/did produce said item in its un-modified form, you have satisfied the burden of proof. Items cloned to a substantial degree which can not be readily distinguished from the import (or OEM) part, "should" be stamped "US" (made) in order to render compelling "assurance". It is not written anywhere that said component MUST be stamped accordingly, while prudent where applicable, or feasible, which is what I perceive begged the question. Items under periods of prohibition otherwise previously available for civilian use such as hi-cap magazines, should be marked with a date and restrictive nature i.e. LE/MIL use only during enforcement of provision. This of course does not apply to non-prohibited items allowable in various levels of representation (i.e. parts count compliance). A gas piston for example could be laser etched, but not always practically, and other methods of marking may compromise inherent strength, so it could not be required. There are many examples of this from the post-ban decade when US made part ensembles were offered for conversion to AK47 configurations. Supporting documentation from the kit assembler/distributor, and tell-tale manufacturing techniques or anomolies sufficed, even subtle cues like a logo stamp, or the implementation of American Walnut in the furniture sufficed as reasonable "assurance". I like to use the "Made in the USA" stamp primarily as a patriotic gesture. Sort of like a salute to the purchaser.

:)

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Guest cleefurd
Sorry to piss in everyone's cheerios, but the only person that that letter is effective for is the recipient.

 

Going out on a limb here since I have not seen the letter....

 

 

 

 

 

But if the letter is;

  • authentic,
  • on a Dept Letterhead (performance of Federal duties/notice)
  • eludes > "an individual may..." as opposed to "...recipient may..."

Then I'm thinking it serves as public evidence to Federal jurisdiction, (not with-standing review by jurisdiction where presented) acceptable as precedent by public inquiry, and non-confidential disclosure.

In any event, if I were to possess said "copy", I would have the copy notarized along with a statement indicating I had compared it to written law, and believed it was relevant to fair comparison/interpretation of the two side-by-side, in temporary "stead" of a personal copy that I was striving to obtain.

 

But I'm too lazy, so I just took some white-out and wrote "Mossberg 590" on the receiver so it smacks of a legal hog-hunter.:D

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Has anybody done this kind of due diligence with BATF for the M2 Tactical? I have read of all kinds of speculation about how many parts are in the M2 that are on the 922r list, but I have not seen any letters or proof from the BATF about their position on what parts would be on their list for the M2. Has anybody seen such evidence?

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