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Replacing Supernova PG stock with Urbino stock - ok with 922r?


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I purchased the Supernova Tactical with pg stock and want to replace the stock with the Urbino stock for the shorter LOP. Am I still in compliant with 922r?


I am replacing an import part with a US part, but I'm sure the gun still contains more than 10 import parts at this point. Am I overthinking here? I've searched 922r topics here and all are about adding a US component or replacing with an import component.


Thanks ahead for any clarification.

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Short answer: Yes, replacing the butt stock with a US made butt stock counts, since the butt stock is one of the parts listed in the regulation.


922r compliance can be confusing, here is a very well done explanation:



Thank you for the link. However, like all the other links to 922r, it reinforces my concern: Just by swapping the stock, I now have an illegal shotgun because it has more than 10 import parts total. The gun has more than 10 import parts out of the box, but since the government ok'd its importation, it is legal to own as is. Once I replaced an item on it, I'm "assembling a shotgun" according to the wording of the laws, and I need to start the count of import parts.


The way I understand it, 922r is all about the magic number of 10 import parts in a shotgun, or stay as is from the factory.

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Yes, it can be confusing.


What you need to do is sit down and look at the parts listed below, and check off the parts your shotgun has.


YES, you can not “ASSEMBLE” a shotgun with MORE than ten foreign parts on it.


BUT…you lawfully purchased an imported shotgun, so …. The key is that you can NOT slap more parts on it from the list below UNLESS they are made in the USA.


That’s why we who want to add the full length magazine tube know we have to replace other Italian parts with USA. The least expensive route is to swap out trigger, hammer, disconnector with USA made parts.


I, on the other hand, like some people wanted to replace my butt stock and wanted a rail forend, so, I was good to go after adding my full length magazine tube.


Let me show you how I did with my Benelli M4.


Here is the list of parts that 922r pertains to, so, in the case of my M4, of this list of twenty mine *had*:



I replaced the butt stock, the magazine tube, the follower, the pistol grip, with USA made parts. So, I’m ok. If however I had purchased an Italian full length magazine tube, or replaced the stock and forend with an Italian made version of those, I’d be in trouble.


Similarly, some guys want to add the Italian made Beretta collapsing stock, so they have to adjust accordingly.


No more than ten foreign parts from that list.


Make sense?

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I urge you to do your own due diligence and not rely on some totally clueless party who quickly volunteers 'information' on a subject he/she knows absolutely nothing about and is unfamiliar with the statute itself.


RE: the question in your OP - I wouldn't sweat replacing the stock on your Super Nova since it's a 'made in the USA part'. Additionally I'm relatively confident these 922® mandated parts counts only apply to semi-autos. Again, I'm making an 'educated guess' here, so DYODD - I suggest you read the statute for yourself.

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I think 922r applies to all shotguns, not just semi autos, but only if you take the gun out of "sporting" configuration, such as putting on a bigger mag tube (to hold more than 5 rounds) or collapsible stock, etc. As you said, you purchased the gun legally, so it was imported in sporting configuration. If all you are doing is replacing your stock pg stock with the urbino, you aren't changing the configuration, so you should be fine so long as the overall length is whatever the minimum has to be, forty inches or so.

Edited by frigatecon
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27 C.F.R. § 478.39 states: … (a) 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 purpose

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  • 1 month later...

So, just for the heck of it, I wrote to BATF, and after about 4 weeks, I got my letter from BATF on this matter:


"Dear Mr. XXXXX:


This is in response to your letter to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). You are requesting a clarification on the regulations in 27 CFR 478.39.


In your letter, you explained that you purchased a Benelli Supernova Tactical 12 gauge shotgun with a standard Benelli pistol grip stock from a licensed manufacturer. You want to replace it with a non-collapsible pistol grip stock manufactured in the United States by Mesa Tactical. You want to know if by replacing the stock on the shotgun you will be in compliance with the regulations in 27 CFR 478.39.


The regulations in 27 CFR 478.39 pertain to assemble of a semiautomatic rifle or shotgun using more than 10 certain imported parts. The activity in which you described above would not fall under the provisions of the regulation since you stated the replacement part is domestically manufactured.


Please be aware that there may be State laws that pertain to your proposed activity. You need to contact your State's Attorney General Office to inquire about the laws and possible restrictions in your State concerning firearms. A list of their offices is available online at www.naag.org.


We trust the foregoing has been responsive to your inquiry. Should you have additional questions, please contact your local ATF office. A listing of ATF office phone numbers can be found at: http:///www.atf.gov/field.



Nicholas E. O'Leary

Chief, Firearms Industry Programs Branch"


Am I understanding this right? From the 3rd paragraph of the response, there's no need for the total part count, as long as the replacement part is domestically made, it's a legal swap? So I can swap in an extension from a US manufacturer and not have to worry about getting more parts to comply? Sounds like the regulations only pertain to those assembling a shotgun from the ground up.

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