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Uncle Builds an AK: Part 2

See part 1 here. All you folks are apparently too lazy to Google. Questions have arisen about compliance [18 USC 922(r)] parts for the AK. Here’s a list, taken from

The 16 countable parts of an AK rifle. No more than 10 of these parts may be imported.

(1) Receiver*
(2) Barrel
(3) Trunnion
(4) Muzzle attachments(flash hiders, brakes, barrel extensions, barrel nuts)*
(5) Bolt
(6) Bolt carrier
(7) Gas piston
(8) Trigger*
(9) Hammer*
(10) Disconnecter*
(11) Buttstock
(12) Pistol grip*
(13) Forearm handguards

(14) Magazine body
(15) Follower
(16) Floorplate

The [bold] parts are the most commonly available U.S. manufactured parts.

On a typical stamped receiver rifle you need to replace 5 parts with no muzzle attachment and 6 parts with a muzzle attachment.

On a typical milled recevier rifle you need to replace 4 parts with no muzzle attachment and 5 parts with a muzzle attachment, because there isn’t a barrel trunion, it is part of the receiver.

When building an AK pistol, these regulations do not apply. You can not have a stock or forward pistol grip on a pistol.

* represent non-imported parts I plan on using.

19 Responses to “Uncle Builds an AK: Part 2”

  1. SayUncle » Uncle Builds an AK: Part 1 Says:

    […] Part 2 is here. The running series can be seen here. […]

  2. Jay G Says:

    Thanks Unc. My AK has no muzzle attachments, hence the 5 parts…

  3. Nate Says:

    You can’t have a forward pistol grip on a pistol? Why’s that? “Sporting purposes” somehow? (I thought that was an AWB artifact, and therefore gone.) I wasn’t planning on building one… but I’m still curious.

  4. SayUncle Says:

    Only on a pistol because that makes it an Any Other Weapon.

  5. Standard Mischief Says:

    So do you have to keep proof of the added US parts, or is the fact that they are stamped “made in USA” enough? Any BATF letters out there?

  6. Standard Mischief Says:

    ^^ I remember reading about building a AR-15 pistol, and the instructions recommended keeping proof (receipts) that stated that all the parts were new and had never been installed on a rifle.

    In theory, if you had installed only one screw that at one time had been installed on a rifle, instead of building a pistol, all of a sudden you had a short barrel rifle. Normally not a problem but for some reason there is the issue of a BATFE special license.

    The other bend-over-backward suggestion was to drill the pins on the upper and lower receiver a different size, so it could never be claimed that the upper receiver of the pistol had ever been installed on the lower receiver of a rifle.

  7. Standard Mischief Says:

    I suppose this silly parts count requirement might mean that if I totally stripped a legally imported (pre-“ban”) AK clone, and then reassembled it without adding any US parts, I might be committing a felony. Any comments?

  8. SayUncle Says:

    Could be. There’s disagreement regarding parts counts. Some argue that if you get a part kit and assemble a gun, you’re not obligated to follow the parts count rules since you did not import a rifle but built one in the US. To be safe, I wouldn’t recommend it since I know of no case where it went to court and I don’t know if the ATF has issued a ruling on it. Regardless, I don’t advise it.

  9. Jay G Says:

    Dunno ’bout the rest of y’all but I don’t want to be a test case…

  10. Standard Mischief Says:

    Hmmm, OK here’s where I’m coming from, instead of build-it-from-scratch, I want to take this horrible thumbhole Norinco gun that I have up till now not been shooting (because of that dang thumbhole stock) and make a shooter out of it.

    To do that (legally) I think I need to replace that un-ergonomic thumbhole bastardization with a US made stock and pistol grip. I think that counts as two parts. Replacing the forward furniture counts as one more. Then I could get a USA made trigger group and put that in (counts as 3 parts).

    At that point, I’ve installed 6 USA parts but I have only removed 5 imported parts. I think I have a legal gun. I also can do “anything” at that point (i.e. insert a magazine composed entirely of import parts or add one of those evil meenie cleaning rod attachments)

    Does that sound right? I’m not, of course, looking for legal advice, merely guidance. If you can guide me to the appropriate BATFE letter, that wouid be even better.

    Bonus Question: I’ve got this slab of maple, I was thinking of making my own furniture for this gun. The maple is grown in the USA and I would make the stock here too. Do I need to do any record keeping or is it OK if I just burn “Made in the USA” in the wood with a soldering iron?

    Extra Special Bonus Question: Is it true that George “Free-Trade” Bush could remove the special preference to US made parts with just the stroke of a pen on an Executive Order?


  11. SayUncle Says:

    These are my opinions and aren’t meant to be legal advice. Ask your lawyer for that:

    I don’t think magazines count or cleaning rods. I think you’d be good to go that way. This guy did it. I would stick with US made parts because they make the best stocks/grips, I think. Plus, if you have a Norinco, it was probably made before there was an import ban.

    Making your own stock would be American made too.

    Yes, Bush could get rid of the import ban by rescinding an executive order.

  12. Standard Mischief Says:

    Thanks for your opinion.

    The Norinco was post-“ban”. it was altered by the maker to comply with the law. That means it got a thumbhole stock,no bayonet lug, and no flash hider. I don’t want to do any drive-by bayoneting, but It would be nice to have a place to attach the cleaning rod. (Normally the bayonet lug does double duty here.)

    Magazines count. I believe you can make a gun where it would be illegal to insert a import magazine. You have them listed above. (14) Magazine body (15) Follower (16) Floorplate.

    If I had only replaced three parts with US made parts, the gun could be legal if I only used Made-in-the-USA magazines (I think)

  13. SayUncle Says:

    If it was made to comply, just make sure replacement parts are american made. Mags count in total or do the parts of the magazine count as well? somehow missed that in the pasted version.

  14. Kristopher Says:

    Magazines count … Body, follower, and floor plate make up three on the 922-r list.

    The flip side is that you could make your own floor-plates to get one more part if needed….

    You could put a us made furniture set on a norinco thumbhole, and use US made mags on it … or just get three more compliance parts … a replacement trigger set from tapco will get it done.

  15. SayUncle Says:

    Wow! So you’re telling me that a rifle may be legal or not depending upon which particular magazines you may use? Feh.

  16. Standard Mischief Says:

    OK, I am taking the following from Boston’s Gun Bible (revised – 2002) ISBN 1-888766-06-9 Chap. 27 “You & the BATF”. His text is italic:
    If the rifle (i.e., receiver) was imported
    Was it imported (not merely made) by 30 September 1990?
    — If Yes, then it’s Pre-import ban and can have all the features.
    — If No, was it imported by 13 September 1994?
    — — If Yes, then it is Pre-crime bill and can have all features if the USC §178.39(c) imported parts count is 10 or less.
    — — If No, then it can have one 18 USC §921(30)(B) feature (i.e, Folding/telescoping/pistol grip stock, bayonet mount, flash suppressor or threaded barrel, or grenade launcher) if the 27 USC §178.39(c) imported parts count is 10 or less.

    (End Boston T. Party. – Start Standard Mischief.)
    OK, so I want to get rid of that awful thumbhole stock. I’d also like to get the cleaning rod re-attached which pretty much means I have to get a bayonet lug installed. My gun was imported after the 30sep1990 “import-ban” [still in effect] but before the 13Sep1994 crime bill {law has sunset]
    My understanding is that even though the crime bill (AKA assault weapons ban or AWB) has sunset, the -Fuck You- from Bush the First is still in effect. What I need to do is replace enough parts on the gun so that of the 16 magic parts that are in the assembled rifle (with a magazine in place), not more than 10 are imported.
    As long as that magic requirement has been met, and stays met, The gun can have all the scary evil features I want, as long as it stays a normal firearm (i.e. long enough barrel, one bang each trigger pull, etc). I can even paint it black!
    Now that it is after 13 September 2004, the second test “was it imported by 13 September 1994?” does not matter. The limits to the following “scary” features no longer applies: Folding/telescoping/pistol grip stock,bayonet mount,flash suppressor or threaded barrel, or grenade launcher (Not realistic– don’t get your hopes up, you still need the special “destructive device” license from the BATFE, this just shows you that the critters making the rules are clueless)
    I think (in other words, the magic incantation is: “I am not a lawyer/ I am not dispensing legal advice/ Not intended to diagnose, cure, treat, or prevent any disease”)
    (switching to question mode)
    These US parts you guys and gals are buying:
    1. Are they stamped US or USA?
    2. Do they come with any records stating they are indeed US made parts?
    3. If so, do you keep a copy “proving” that they are US made?
    4. What would keep someone from taking a imported part and stamping “made in USA” on it and selling it to me?

  17. SayUncle Says:

    Dunno if they’re stamped or anything. I have a century WASR that is supposed to be compliant but I doubt the century shop stamps all the parts.

    Even the courts have said: with guns the citizen acts at his peril.

    No shit.

  18. My Quiet Life » uncle builds an AK Says:

    […] SayUncle is running a cool series on his blog as he builds a Kalashnikov. […]

  19. SayUncle » Uncle Builds an AK: Part 3 Says:

    […] If you’re new to the AK Series, here’s part one, on general how to. And here’s part 2 on legal and compliance info. When we last left off, I was in the process of sanding and sawing off the forward pistol grip. I stripped the varnish, cut off the forward grip and sanded it down. I am sad to report the wood underneath all that varnish is hideously ugly. See: […]

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