Your new SKS and 922R Compliance for the new shooter

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  • A lot of new shooters are buying/modding SKS rifles.
    I figured I would put this out there to help prevent the uninformed from getting themselves in trouble at a later date.
    No one has been convicted of this, to my knowledge, but it's a good CYA for all to abide by...especially in our current gun unfriendly environment.
    Title 18 of the US Code (18 USC), Chapter 44 Section 922 is Federal Law and applies to both imported shotguns and rifles.
    There is a list of 20 possible parts and the number of parts per firearm varies, according to model.
    The law is if you change ONE part, then you have to change enough parts so that no more than TEN parts of the firearm are imported. The balance of the parts have to be US made, which again varies according to model.

    Most SKS rifles in original form have 14 parts, see below.
    The Yugo 59/66 has an extra one for a total of 15.
    This means in order to be legal no more than 10 parts can be imported, if you change one part, you need to change enough parts to have no more than 10 parts that are imported.
    This means that if you change one part, that you need to change at least 4 or 5 parts accordingly.
    Adding a Tapco stock adds a pistol grip and adding a detachable magazine now adds a floorplate.
    Most say...this is OK, because now I have 5 total US parts, buttstock, handguard, pistol grip, magazine and pistol grip.
    Problem is that 2 of those 5 parts were not in the original configuration and now bring the total parts count to 16 or 17 of the Federally listed parts.
    So in effect you only changed 3 of the original parts and added 2 to the overall total.
    This means that you need a Tapco Stock set, a US made handguard, a US made magazine and still need a minimum of one extra US made part, of your choice, to be compliant.
    If you only go to a monte carlo style stock, you still need at least 3 more parts to be legal...a handguard, a magazine and one more part of your choice.

    SKS Parts per the Federal List in Normal Configuration
    1. Receiver.
    2. Barrel.
    3. Muzzle attachment. Yugo M59/66A1 Only
    4. Bolt.
    5. Bolt carrier.
    6. Gas piston.
    7. Trigger housing.
    8. Trigger.
    9. Hammer.
    10. Sear.
    11. Disconnector.
    12. Buttstock.
    13. Forearm/handguard.
    14. Magazine body.
    15. Follower.

    Total Parts in original configuration:
    Yugo 59/66 = 15
    All other models = 14

    Tapco Stock and Handguard set added - Total Parts:(adds pistol grip)
    Yugo 59/66 = 16
    All other models = 15

    Tapco Stock and Handguard set added with US made magazine - Total Parts:(adds pistol grip and floorplate)
    Yugo 59/66 = 17
    All other models = 16

    It's very easy to be ignorant and in violation of this.
    Like we have seen many times in the past, ignorance is not an acceptable excuse for non-compliance.
    That's the reason they made it that way IMHO, a very forward-looking law, for possible use at a later date.
    Know the law and make sure you are compliant.
    Due to parts availability, it is VERY difficult to change any parts and be able to change enough parts to be both compliant with 922R AND retain status as an unregulated SKS in MD.
    If you change to Monte Stock/handguard and keep the fixed mag, you still need 2 more US made parts, which can be difficult if you omit the magazine.
    Removal of the bayonet does not count, as they thought ahead and it is not a counted part.
    Some argue that all stocks have a pistol grip, but that is a gray area that is better not tread upon IMO.
    They did their homework on this one, back in the day, mostly to make throwing a foreign parts kit together with a US made receiver alone illegal.
    Other miscellaneous parts weren't as available, back the, as they are now.
    Clear as mud????:D
     

    Machodoc

    Old Guy
    Jun 27, 2012
    5,745
    Just South of Chuck County
    Good job! We should all keep in mind, as well, that even the pro-gun lobbyists are pushing congress to start enforcing the gun laws that we already have, rather than enacting new ones. This is one of those laws that we already have, and all indicators are that just because nobody has been prosecuted for it in the past, that doesn't mean that there won't be aggressive enforcement in the future. If you have a C&R that you've modified, but that doesn't meet all the requirements, you might want to remind yourself of that before you take it down to the local range.
     

    Machodoc

    Old Guy
    Jun 27, 2012
    5,745
    Just South of Chuck County
    This site noted is for NON-C & R SKS's. If that makes a difference.....

    Once you start swapping out parts, it becomes a non-C&R firearm. Exactly where is the line drawn for this? As I've said before, government lawyers intentionally write in gray areas when they create laws. (That from a former career FAA lawyer.) Doing so gives them the ability to not necessarily have to pursue every minor infraction ... but it also gives them leeway to go after you if they really want to get you. Remember that Al Capone, one of the most infamous gangsters in our history, was jailed for tax evasion.
     

    OnTarget

    Ultimate Member
    Mar 29, 2009
    3,154
    WV
    Not necessarily taking about SKS', but someone was saying the other day that it was the swapping of the stock (say to folder, telescopic, etc.) that made the 922r rule go into effect. They suggested that no stock change meant no 922r. Any truth to this?
     

    Chaunsey

    Ultimate Member
    Nov 28, 2009
    3,692
    brandywine MD
    Nope. Change any part and you have to comply w/ 922r.

    depends, only if you modify the rifle.

    replacing parts, with parts that are the same is fine, for example your gas piston snaps in two, and you buy a replacement.

    adding stuff to the gun is not an issue either, like slapping on a bipod.


    its when you replace the stock with a different or synthetic stock, or replace the 10 round mag with a 20, or maybe even replace the receiver cover with one that has a built in scope mount.
     

    jaycee2004

    Active Member
    Apr 17, 2009
    572
    Cambridge
    So am I correct in saying that with my M59/66a1 Yugo, I change the stock which counts as three parts, the magazine, which count as three parts and the handguard/ gas tube which counts as one part, I would be 922r compliant? I just want to make sure that when I complete my assembly and lord forbid have to register it, I am also gonna stay out of the federal pokey
     

    Chaunsey

    Ultimate Member
    Nov 28, 2009
    3,692
    brandywine MD
    Unfortunately, 922r does not differentiate between replacement of parts. The law has to do with "assembly" of a firearm, but does allow an exception for disassembly and reassembly for cleaning, using the same original parts,and removal and replacement of magazines (of course). As soon as one part is changed, regardless of part country origin or configuration, according to the ATF you have now met the assembly criteria....and can have no more than 10 foreign made parts. Same goes for adding parts, as you have now assembled the firearm.

    ATF response letter below:



    yes but you have to realize that we're specificially discussing C&R firearms here.


    a yugo SKS, as received is an illegal feogn made military semi auto.

    the only reason we are allowed to have it, is because it is designated as C&R, therefore it is exempt from needing to comply with 922r at all.

    the question is not, what constitutes assembly or whatever, the question is, what can you do without voiding the firearm's C&R classification.
     

    Chaunsey

    Ultimate Member
    Nov 28, 2009
    3,692
    brandywine MD
    So am I correct in saying that with my M59/66a1 Yugo, I change the stock which counts as three parts, the magazine, which count as three parts and the handguard/ gas tube which counts as one part, I would be 922r compliant? I just want to make sure that when I complete my assembly and lord forbid have to register it, I am also gonna stay out of the federal pokey

    you will not have to register it, period.

    even if you turn it into an assault weapon, it is grandfathered, there is no registration.

    and it only becomes an assault rifle if you change it to use detachable magazines.

    that said, with the yugo SKS you need to replace 5 parts, there are 15 "compliance parts" on the yugo SKS.

    the stock and handguard are 2 parts.

    magazine is 2 parts.

    you still need one more part, the best option is to replace the gas piston with a US made one, since thats a relatively affordable part and it doesnt change anything with the function or look of the rifle.
     

    J-Dog

    Ultimate Member
    Mar 9, 2012
    1,789
    Might be a dumb question, but I can't seem to find a clear cut answer, and it seems like it would go with the subject of this thread.

    I have long arms, and I'd like a little more length of pull on my Yugo M59/66 SKS. Can I add a recoil pad, or butt pad extender of some kind (either slip on or utilizing the original hardware) onto my stock and still maintain C&R/922r compliance?

    I'm not sure, since I wouldn't be changing the stock, but I would be, I guess, technically adding a US made part. However, it's not clear if the rubber recoil pad counts as a part for 922r purposes, or if it's only the actual wood stock that counts (which I won't be changing). To me, it seems like the pad wouldn't count, but I figured I'd ask you guys' thoughts.
     

    Chaunsey

    Ultimate Member
    Nov 28, 2009
    3,692
    brandywine MD
    Might be a dumb question, but I can't seem to find a clear cut answer.

    I have long arms, and I'd like a little more length of pull on my Yugo M59/66 SKS. Can I add a recoil pad, or butt pad extender of some kind (either slip on or utilizing the original hardware) onto my stock and still maintain C&R/922r compliance?

    I'm not sure, since I wouldn't be changing the stock, but I would be, I guess, technically adding a US made part. However, it's not clear if the rubber recoil pad counts as a part for 922r purposes, or if it's the actual wood stock that counts (which I won't be changing). To me, it seems like the pad wouldn't count, but I figured I'd ask you guys' thoughts.


    should be fine, adding stuff doesnt tend to change the C&R status, its usually when you remove and replace or heavily modify stuff.
     

    J-Dog

    Ultimate Member
    Mar 9, 2012
    1,789
    Cool. Thanks. I just wanted to be sure I wasn't running afoul of some law or ordinance by making the rifle fit me a little better. :)
     

    rico903

    Ultimate Member
    May 2, 2011
    8,802
    AM I the only one who finds this original post confusing as hell? Why does changing a stock to an American made stock require you to change several other parts to be in compliance? Aren't you in effect reducing the # of imported parts and adding American parts?
     

    AC MkIII

    Active Member
    Feb 18, 2011
    929
    Calvert
    What if you you don't have a c&r and you buy one from a local shop, you're nics'd and you take your unreg'd sks home.
    How does 922r apply?
    I am a little slow so bear with me.
     
    Last edited:

    lordphoenix140

    Captain
    Jun 21, 2015
    4
    Glen Burnie
    This is an old thread but I wanted to clarify for anyone that finds this that it is the number of FOREIGN parts that matter, not how many US parts are on the rifle.


    So am I correct in saying that with my M59/66a1 Yugo, I change the stock which counts as three parts, the magazine, which count as three parts and the handguard/ gas tube which counts as one part, I would be 922r compliant? I just want to make sure that when I complete my assembly and lord forbid have to register it, I am also gonna stay out of the federal pokey


    Note: By the above logic this gun would be legal [start with 15 parts and swap 6] but in fact the gun would still be ILLEGAL. This is due to a combination of failure to realize that the handguard is included in the "3 parts" added by changing the furniture and most importantly that the above part count is including US parts that are being added to the gun without removing a foreign part.

    The Yugo in stock configuration has 15 parts. A detachable magazine has 3 parts but when you put on a US made mag you only reduce your foreign parts count by *2* because the stock rifle doesn't have a floorplate. Also, changing the furniture gives you 3 US parts if you buy one with a pistol grip [stock, pistol grip, and handguard] but you are only removing *2* foreign parts to do this because the stock rifle does not have a pistol grip. That leaves the final foreign parts count at 11, which is greater than 10, and thus illegal.

    The checklist on the gunwiki is a great resource for determining the foreign parts count of your rifle:

    http://thegunwiki.com/Gunwiki/BuildSKSVerifyCompliance
     

    Machodoc

    Old Guy
    Jun 27, 2012
    5,745
    Just South of Chuck County
    More germane to this thread, though, is that an SKS loses its C&R status easily if you start swapping parts with some that are not original or reproduction of the originals. Changing the sights, for example, is permitted, but putting a "tactical" plastic stock on it makes it no longer a C&R rifle.
     

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