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Parts Count Info

Information all copied from AK-47.net forums:

2 BIG areas of concern:

 - 1994 Assault Weapons Ban features

 - 1989 crime bill U.S.-made parts count quota

These two are the biggest issues.  The first issue, the AWB, is "sunseted" aka "dead" legislation as of Sept. 14th, 2004.  The 1989 crime bill has no expiration and therefore the U.S. parts count quota will remain in effect.

Parts Count Information

When an AK was imported and nobody had monkeyed with it yet, it had either 14, 15 or 16 countable parts. This is a list of the parts that apply specifically to AK's.

(1) Frames, receivers, receiver castings, forgings or stampings 
(2) Barrels 
(3) Mounting blocks (trunnions) 
(4) Muzzle attachments 
(5) Bolts 
(6) Bolt carriers 
(7) Gas pistons 
(8) Triggers 
(9) Hammers 
(10) Disconnectors 
(11) Buttstocks 
(12) Pistol grips 
(13) Forearm handguards 
(14) Magazine body 
(15) Followers 
(16) Floorplates 

A milled rifle without a muzzle brake has 14 parts because it doesn't have a trunnion. The part that serves that purpose is built in to the reciever.

With a muzzle brake makes 15.

A stamped rifle without a muzzle brake has 15 parts. Pesky trunnion.

With a brake 16.

To get that pistol grip on there you have to change the status of the rifle from that of an imported product,(e-vil assault rifle), to that of a domestically manufactured product,(modern sporting rifle). 

A domestically produced sporting rifle may have no more than 10 imported parts for it to still be considered domestic. So, depending on whether you have a milled or stamped rifle and whether or not it has a muzzle brake, you will have to replace up to 6 of the imported parts with made in the USA ones.

That's a key phrase there. You can't just slap on some US doohickies and go. You have to replace parts that were on the original rifle with made in the US ones. That's why it works in our favor that the butthole stocks are counted as 2 parts during the parts count for importation. If it were only counted as one part you would be adding another part to the total count when you put a pistol grip on. It could easily be offset by adding a US pistol grip, just like a made in the US muzzle brake will, in effect, offset itself but it would add an additional twist to an already convoluted subject.

Replacement US parts include:

Buttstock 1 
pistol grip 1 
upper and lower handguards 1 
muzzle brake 1 
gas piston 1 
hammer 1 
trigger 1 
disconnector 1
magazine body 1 
follower 1 
floorplate 1 
reciever 1 

Please note that the upper and lower handguards are counted as one part. If you only replace one or the other it will not be counted as a US part regardless of what is molded into the plastic. Both the upper and lower must be of US manufacture for it to count toward changing it's import status. Also, a muzzle nut is not an attachment if it is secured properly but a brake is an attachment regardless of whether or not there are threads holding it on. 

In Short:
A milled AK rifle without a muzzle brake needs 4 US parts.
W/ brake, 5.

A stamped AK rifle without a muzzle brake needs 5 US parts.
W/ brake 6.

 

============

Information gleaned from the original Soupbowl website - the scan of the original ATF letter, and the chart Soupbowl put together identifying the parts based on the letter.  The website statued that the list was compiled based on the letter, AND on the assumption that a pistol group would be added to the build.  Also, additional configuration assumptions went into the list, such as muzzle attachments, etc.  I am leaving the list in its original format.

   

NOTE: The count for the Saiga Shotgun was compiled with the assumption that a pistol grip would be added.  Note the document indicates a *DEFAULT* (out of the box) Saiga Shotgun configuration has only 13 parts!!!
Imported PARTS
16 parts
15/16 parts
17 parts
17 parts
17 parts
17 parts
14 parts
17 parts


UZI
GALIL 
AK's
DAEWOO DR 200
FN/FAL 
SAR 8 & SAR4800
H&K MP5
H&K XG3
Siaga

Shotgun
Sig 550-1SP
1
 Frames,recievers, reciever castings, forgings or stampings
X*
X*
X
X*
X*
X*
X
X
2
Barrels
X*
X*
X
X*
X*
X*
X
X
3
Barrel Extensions

X



X
4
Mounting Blocks, Trounions
X*
X*%

X*
X*

5
Muzzle Attachments
X*%
X*
X*
X*
X*

6
Bolts
X
X
X
X
X
X
X
X
7
Bolt Carriers
X
X
X
X
X
X
X
8
Operating Rods
X
X
X
X*
X*
X
9
Gas Pistons
X*
X
X*

X
X
10
Trigger Housings
X

X*
X
X
X
11
Triggers
X
X*
X*
X*
X*
X*
X
X
12
Hammers
X
X*
X*
X*
X*
X*
X
X
13
Sears
X


X*
X*
X
14
Disconectors
X
X*
X*
X*

X
15
Buttstocks
X
X*
X
X*
X*
X*
X
X
16
Pistol Grips
X*
X*
X
X*
X*
X*
X
X
17
ForeArms/ Handguards
X*
X*
X
X*
X*
X*
X
X
18
Magazine Bodies
X*
X*
X
X
X*
X*
X
X
19
Magazine Floorplates
X*
X*
X*
X*
X*
X*
X
X
20
Magazine Followers
X*
X*
X*
X*
X*
X*
X
X