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Since my last post was very informative, I figured I'd make one for parts and for 922r compliance. I'll start by first sharing the information I received via an email from the ATF.


This refers to your recent email to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), Firearms Industry programs Branch concerning the lawfulness of modifying a Benelli M4 shotgun, and the possible impact of the restrictions contained in the amended Gun Control Act of 1968, 18 U.S.C. § 922(r).


As you may be aware, § 922(r) prohibits assembly of certain semiautomatic rifles and shotguns from imported parts.  Also, the implementing regulations contained in 27 CFR § 478.39 include the stipulation that “no person shall assemble a semiautomatic rifle or any shotgun using more than 10 of certain imported parts, if the assembled firearm is prohibited from importation under 18 U.S.C. § 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes.” 


These parts are as follows:

 (1) Frames, receivers, receiver

castings, forgings, or castings.

(2) Barrels.

(3) Barrel extensions.

(4) Mounting blocks (trunnions).

(5) Muzzle attachments.

(6) Bolts.

(7) Bolt carriers.

(8) Operating rods.

(9) Gas pistons.

(10) Trigger housings.

(11) Triggers.

(12) Hammers.

(13) Sears.

(14) Disconnectors.

(15) Buttstocks.

(16) Pistol grips.

(17) Forearms, handguards.

(18) Magazine bodies.

(19) Followers.

(20) Floor plates.


Features which are not recognized as sporting on shotguns include, but are not limited to, a magazine capacity greater than 5 rounds, folding or telescoping stocks, pistol grips that protrude conspicuously beneath the action of the weapon, a bayonet or bayonet mount, a flash suppressor or threaded barrel designed to accommodate a flash suppressor, a grenade launcher and night sights


As an example, a shotgun having a magazine capacity of more than five shells is prohibited from importation under 18 U.S.C. § 925(d)(3) since it fails to meet sporting firearms criteria.  Therefore, it is a violation of § 922(r) to assemble such a shotgun from more than 10 of the imported parts specified § 478.39.  However, assembly of certain semiautomatic rifles or shotguns using 10 or fewer of these imported parts is not prohibited under this section.


The Benelli M4/Super 90 shotgun: When equipped with the standard buttstock or the fixed pistol-grip buttstock assembly it contains the following parts from the list presented above:

1.            Receiver.

2.            Barrel.

3.            Bolt.

4.            Bolt carrier.

5.            Gas piston(s).

6.            Trigger housing.

7.            Trigger.

8.            Hammer.

9.            Disconnector.

10.          Buttstock.

11.          Forearm(s).

12.          Magazine body.

13.          Follower.


Regarding the fixed pistol-grip stock of the Benelli M4/Super 90 shotgun, ATF has determined that this assembly consists of a buttstock only.  This assembly has an integral pistol grip molded-in, and is designed to accept a “rubber grip” accessory.  This accessory acts only to provide a comfortable gripping surface and is not considered a “pistol grip.”  Also, we should point out that the Benelli M4/Super 90 shotgun telescoping stock incorporates both a buttstock and a pistol grip.  The pistol grip of this stock assembly is designed to accept a “rubber grip” accessory.  This accessory acts only to provide a comfortable gripping surface and is not considered a “pistol grip.”


In order not to be in violation of 922(r) once the Benelli M4 is in a non importable configuration (magazine which can hold more than 5 shots etc.) no more than 10 of the parts listed above contained in or on the assembled firearm can have been made / imported from overseas.


We thank you for your inquiry and trust that this has been responsive.


Michael S Knapp

Firearms Enforcement Specialist

Bureau of Alcohol, Tobacco, Firearms and Explosives

Firearms and Explosives Industry Division

Firearms Industry Programs Branch

With that out of the way, I would like to know what are the best US made parts to get for upgrading a Benelli M4 11707 while making it 922r compliant. I'm wanting to get the 7 round tube and the collapsible stock.

I'm aware of FFT and TTI as well as Carrier Comp. I've heard good things about the ladder and went ahead and ordered a full length titanium magazine tube from them. Since it comes with a follower, that would make 2 US parts and, based on my understanding, I would need 2 more parts replaced to have both the full length tube and collapsible stock. What other parts are worth replacing and by which manufacturer? I am also interested in getting the TTI extended carrier, the TTI oversized safety, the GG&G bolt release pad, and the GG&G charging handle:

TTI Carrier: https://tarantacticalinnovations.com/tti-benelli-accuguide-extended-carrier/

TTI Safety: https://tarantacticalinnovations.com/tti-oversized-benelli-ultimate-safety/

GG&G Pad: https://www.gggaz.com/benelli-m4-tactical-bolt-release-pad.html

GG&G Handle: https://www.gggaz.com/benelli-m4-tactical-charging-handle.html

Are these parts worth it?

Any additional information and advice would be greatly appreciated.

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