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922r and ONLY the collapsable stock


Smokin

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i liked the "look and feel" of the benelli collapsible stock on my M4. all things being equal i would also like the "functionality" of the collapsible stock, but since a "collapsible" stock opens a can of worms (especially in commifornia) i opted to simply have a gunsmith "lock" my collapsible stock at the midway point. problem solved. i no longer have a collapsible stock. it's now a "fixed" stock that just happens to "look" like a collapsible stock.

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Okay. I'm confused. How would a US collapsible stock be in violation of 922r? Let's say you start off with a stock M4, you remove the standard pistol grip stock and replace it with the available Benelli collapsible stock. All you have to do is replace one part on the M4 with a US part, like the follower, because by adding that stock you're adding another foreign part because it's considered "2 pieces" by some law writing moron. Replacing the follower will put you back where you were. I was under the impression that it was the full capacity magazine that put you in an entirely different parts count bracket, not the stock.

 

Now, let's take that same stock M4 and replace the stock with a US made collapsible stock (if it existed). You should be good to go because your foreign parts count is actually one less than it was before the stock was changed and since you kept the neutered magazine tube you're still in the 13 foreign parts bracket. You now have 12 foreign parts. Is my understanding is wrong. :eek:

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If you only replaced the Benelli stock with a US made one, it would count as 1 US made part. You're only counting parts that you are removing. It would be like if you had added the Urbino stock.

 

So in total, you would still need 2 more parts to be compliant. The full length magazine tube and the follower would suffice.

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Okay. I'm confused. How would a US collapsible stock be in violation of 922r? Let's say you start off with a stock M4, you remove the standard pistol grip stock and replace it with the available Benelli collapsible stock. All you have to do is replace one part on the M4 with a US part, like the follower, because by adding that stock you're adding another foreign part because it's considered "2 pieces" by some law writing moron. Replacing the follower will put you back where you were. I was under the impression that it was the full capacity magazine that put you in an entirely different parts count bracket, not the stock.

 

Now, let's take that same stock M4 and replace the stock with a US made collapsible stock (if it existed). You should be good to go because your foreign parts count is actually one less than it was before the stock was changed and since you kept the neutered magazine tube you're still in the 13 foreign parts bracket. You now have 12 foreign parts. Is my understanding is wrong. :eek:

 

After a few here replied, I started to reseasrch more. I "THINK" the issue is that whenever you replace EITHER the magazine or the collapsable stock, you now have a shotgun that meets more than "one" of the evil features. In its original form, it only has a 5 round capacity, and a pistol grip (which is its only evil feature). When you increase the capacity OR change the buttstock, you now have 2 evil features. Once you are in that territory, you have at least 3 pieces to replace. Since the pistol grip and stock are 2 pieces, you need 4. There arent 4 pieces available currently to replace. If Im wrong someone let me know....

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After a few here replied, I started to reseasrch more. I "THINK" the issue is that whenever you replace EITHER the magazine or the collapsable stock, you now have a shotgun that meets more than "one" of the evil features. In its original form, it only has a 5 round capacity, and a pistol grip (which is its only evil feature). When you increase the capacity OR change the buttstock, you now have 2 evil features. Once you are in that territory, you have at least 3 pieces to replace. Since the pistol grip and stock are 2 pieces, you need 4. There arent 4 pieces available currently to replace. If Im wrong someone let me know....

 

You sound like you're confusing these 992r rules with the expired assault weapons criteria. You remember -- bayonet lug, flash supp., pistol grip, etc. It's not the same thing. Plenty to read on this subject in addition to pretty clear guidance above. Research the parts that constitute an M4 as determined by the ATF. IF you start messing around with the configuration then you need to worry (if you care). If you pop on the collapsible stock and the mag tube AND then replace the follower and the fore-grip, you're still short of the required domestic content. A few solutions may or may not be in the offing.

Edited by BigHat
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Okay. I'm confused. How would a US collapsible stock be in violation of 922r? Let's say you start off with a stock M4, you remove the standard pistol grip stock and replace it with the available Benelli collapsible stock. All you have to do is replace one part on the M4 with a US part, like the follower, because by adding that stock you're adding another foreign part because it's considered "2 pieces" by some law writing moron. Replacing the follower will put you back where you were. I was under the impression that it was the full capacity magazine that put you in an entirely different parts count bracket, not the stock.

 

Now, let's take that same stock M4 and replace the stock with a US made collapsible stock (if it existed). You should be good to go because your foreign parts count is actually one less than it was before the stock was changed and since you kept the neutered magazine tube you're still in the 13 foreign parts bracket. You now have 12 foreign parts. Is my understanding is wrong. :eek:

 

If the law was that you just couldn't increase the import parts, it would make more sense; but this isn't the case. (Frankly, if 922r was to make any sense, it would have to be stricken from law altogether.) If you alter the firearm from its BAFTE-approved importable condition, it must have the total "countable" imported parts down to 10 or fewer. Reducing the parts count from 13 to 12 is still a violation of the law.

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If the law was that you just couldn't increase the import parts, it would make more sense; but this isn't the case. (Frankly, if 922r was to make any sense, it would have to be stricken from law altogether.) If you alter the firearm from its BAFTE-approved importable condition, it must have the total "countable" imported parts down to 10 or fewer. Reducing the parts count from 13 to 12 is still a violation of the law.

 

In the case of the collapsable stock, you would be at 14 parts since you upped the foreign count by 1 (the grip and the stock are separate pieces?).

 

Is it that you modified it? or is it counted by feature?

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In the case of the collapsable stock, you would be at 14 parts since you upped the foreign count by 1 (the grip and the stock are separate pieces?).

 

Is it that you modified it? or is it counted by feature?

 

922r becomes an issue (from a legal standpoint) as soon as you make any modification to an imported firearm. It doesn't matter if the "countable" parts count goes up or down. If that parts count is over 10, the firearm is in violation of the law. The only 922r-compliant configuration with a "countable" parts count over 10 is the configuration (or configurations) that was approved by BAFTE for that specific model number.

 

As for the number of parts: If you take the OEM pistol grip stock (1 part) off and replace it with the imported skeleton stock (2 parts) then, yes, the "countable" parts count increases from 13 to 14. You would then need to replace 4 other "countable" parts with US-made compliance parts.

 

I, like others here, am not aware of any mass-produced parts that will get you in compliance to use the skeleton stock at this point. Magazines, followers, and forearms are available to replace 3 parts; but a fourth part is elusive. Some have gained compliance by having pistons or fire control components custom made, but nobody is willing to stake their reputation (or lives) on parts that haven't gone through the proper safety testing and certification process. I'm eager to find out who Kip pushed his fire control parts project off on. I've got a skeleton stock sitting on a counter waiting to be installed. (Yes, although 922r is stupid, I am compliant with the law.)

 

ETA: The parts count I have is based on general knowledge, not first-hand information from BAFTE. Do not misconstrue what I'm saying as legal advice; it is not intended to be such.

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To make a small addition to Leo's excellent post above, remember that ruling provided to one party by the ATF does not automatically apply to others, even though it probably isn't a huge deal.

 

While I haven't done it myself, many have solicited a ruling on the M4 (regarding the number of parts) and then used it as their basis for compliance. For example, I have a US made follower that isn't marked as such, so I keep the receipts / product descriptions all in one place. When I can get 922r compliant, I'll probably write them for a ruling so should it ever become an issue I have the requisite documentation to steer clear of trouble with the feds.

 

I have to think that showing enough interest to write the ATF and then save documentation of parts changes (especially small items like FC parts, etc) would not be deemed typical behavior for one with criminal intent.

Edited by BigHat
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