Just researched this same question.

The following was what it currently considered the "answer":

A milled-receiver AK has 14 922r "parts" (15 if you have a muzzle-brake).

A stamped-receiver AK has 15 922r "parts" (16 if you have a muzzle-brake).

Essentially, the maximum number of US-made parts you will be required to substitute is 6, and that is if you have a stamped-receiver and a muzzle brake.  OTOH, if you, say, have an Arsenal SLR-95 from Bulgaria (milled receiver) and no muzzle brake, you would only need to substitute 4 US-made parts.

Anticipating the next question, the following US-made parts are readily available to substitute your required number of parts to be 922r-compliant:

- buttstock
- pistol grip
- upper and lower handguards (note: require both to count as "1" part)
- muzzle brake
- gas piston
- hammer
- trigger
- disconnector
- receiver
- follower (magazine)
- floorplate (magazine)

Disclaimer: I am not a lawyer.  I am not a 922r-legal specialist.  The above information is simply a summary of the consensus of many AK-47 owners construction of the 922r regulations as available by a search of the Net.

HTH

http://home.comcast.net/~guncollector/pics/kkitty_awbsunset.jpg

I'm wanting to get an AK soon, and will be putting an ACE folder on it.  Does the stock count as one part, and the stock adapter used to attach it to the rifle count as another, or is this all considered one part?  Thanks in advance.

Quoted: OK, this is probably one of THE most asked questions: What are the parts that need to be replaced to be 922r compliant? (1) Frames, receivers, receiver castings, forgings or stampings (2) Barrels (3) Mounting blocks (trunions) (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 An gun can contain no more that 10 "imported" parts. The floorplate and follower count as one part each. Both handguards count as 1 part, the pistol grip counts as 1, as well as the stock is 1. By replacing the FCG with an American made version this counts as 3 parts replacement.

Doesn't the AK have two trunnions?  A front and a rear.  Do they both count as a part, both count as one part or only one is considered a 922r part?  Also, does the sear and disconnector count as one part?  Does a semi-auto AK even have a sear?  Finally, there were some other items on a list I pulled from the BATF website such as a barrel extension, operating rod and trigger housing.  I know the AK doesn't have an operating rod but what do they mean by barrel extension and trigger housing?  If I get these answers cleared up then I think it will all finally make sense to me.

I ordered a AK-74 parts kit from K-Var today and am very anxious to get this whole thing figured out so I can get her assembled.  

I appreciate the time and help.

ETA:  Here is the link to a thread I posted earlier today.  It contains the list of parts that was listed on the BATF website.

Appearantly only the front trunnion counts. I've asked that months before. Its thought of as a rear tang and not as a true trunnion. Word semantics.

Quoted: I'm wanting to get an AK soon, and will be putting an ACE folder on it.  Does the stock count as one part, and the stock adapter used to attach it to the rifle count as another, or is this all considered one part?  Thanks in advance.

Any rifle you purchase allready has enough US parts.

So long as you do not replace a US part with a foreign part (the US parts are normally the FCG (H/T/S), pistol grip, and gas piston)....

So swapping stocks does not create a US parts issue...

ok i know this is going to be stupid question? do u still have to have 5 parts USA made to put a folding stock/ pistel grip on a AK thx. If so do u know where a good place to get the parts. Also where can i get a folding stock at reasonable price not $300 like i saw at one place

According to how BATF&E applies countable parts from the 20 part master list:
An AK type rifle does not have a barrel extension. An AR15 type rifle is an example of a rifle that does have a barrel extension.
An AK type rifle does not have an op rod. A G3/CEMTE type rifle is an example of a rifle that does have an op rod.
An AK type rifle does not have a trigger housing. An FAL type rifle is an example of a rifle that does have a trigger housing.

Harlan
FAC

ps: Remember that there is no federal requirement for U.S. parts for compliance purposes. There is a federal limit of ten imported parts. The purpose of U.S. parts is to reduce the imported parts count and to make the rifle functional.

IIRC, the now-defunct AWB declared that a thumbhole stock counted as a PG + buttstock.  Is that correct, and how does that affect the parts count now.

The AWB had absolutely no effect on 922r compliance.

If your rifle is a thumbhole stock model (let's use a MAK-90 as the example here, because I have one), you will still need at least 5 US-made parts for compliance (the MAK-90 has no muzzle attachment, hence why it's only 5).

If you were to put on one of those nifty polymer stock sets made here in the US, and install a US-made fire control group, you now have only 9 foriegn parts, and 6 US parts, hence, you're more than compliant.

You get no bonus for over-compliance.

As I've been reminded numerous times - it's not how many parts you take off, it's not how many US parts you put on - it's how many foriegn parts remain in the rifle.  Even if the thumbhole stock only counted as one part, there's no "shortcut" or bonus when you replace one part with two - there's still 13 or 14 foriegn parts in the rifle.

I I am quite familiar with 922(r) compliance, but I have a very specific question about thumbhole stocks.  
The question of where thumbhole stocks were classified came up on another board, and I seem to remember as that author did that the AWB is where thumbholestocks became classified as PG, not 922(r).  

I have searched through both 27 CR 478 and 18 U.S.C. 922, and I have not found where a thumbhole is defined as a PG.  


27 CR 478

18 U.S.C. 922

I have also been throught the AWB, and cannot find it there, either.  Maybe it's in an ATF ruling.

AWB

Per ATF ruling (and no, I don't have them around here), I believe the thumbhole counts as two parts.

Further, if the rifle was imported with one, then it's all good and well.

Taking a post-ban (pre-sunset), say, FAL, and taking off the PG/buttstock and putting on a thumbhole, in order to put a flash hider on the rifle was a big nono, as the ATF ruled that the aftermarket thumbhole counted the same as an unconnected buttstock/PG.

Thanks for replying again.  I know I've seen this before, but I can't for the life of me find it.  And I spent probably four or five hours on the ATF website today.



I will also add this link that I found in the General AK forum:


1998 ATF ruling bannin importation of firearms that CAN accept magazines greater than 10rds.

How about this situation: I purchased a WASR-10 high capacity model with the "Daragunov" thumbhole stock.  Does this already have the requisite number  of  US made parts?  I think it has to in order to accept a double stack magazine, despite the thumbhole stock, correct?

I'm planning to add a regular wood stock and a US pistol grip, so I would not be increasing the number of imported parts, but I want to be certain that it's not currently all romanian.

It very likely is ALL Romanian.

There's a lot of stuff still allowed for import, and there are no parts count restrictions on import.

The WASR-10 has a thumbhole stock, and originally was built to only accept single stack magazines.

There's no restriction on people milling out the receiver in order to accept double-stacks, which is why there's a LOT of WASR-10's available in that form.

If you want to remove the thumbhole, and put normal furniture on it, you need to comply with the parts count, 5 or 6 US parts.

Quoted: The WASR-10 has a thumbhole stock, and originally was built to only accept single stack magazines. There's no restriction on people milling out the receiver in order to accept double-stacks, which is why there's a LOT of WASR-10's available in that form.

so even if  it was imported  as a single stack  all I have to do to make it a double stack is hog out the mag well ?? no parts count worries??
and do any of you know the statute ,or rule , or code that applys to this?

Quoted: Quoted: The WASR-10 has a thumbhole stock, and originally was built to only accept single stack magazines. There's no restriction on people milling out the receiver in order to accept double-stacks, which is why there's a LOT of WASR-10's available in that form. so even if  it was imported  as a single stack  all I have to do to make it a double stack is hog out the mag well ?? no parts count worries?? and do any of you know the statute ,or rule , or code that applys to this?

If your WASR-10 already has the US parts and the buttstock/PG, you're good.  If your WASR-10 still has the thumbhole stock and is as-imported, you're good.

There's no law/statute/rule/code that I know of, because there's nothing against this.  There's no restrictions on any rifles on what kind of magazine they'll accept, as far as I know, and there's no federal law on magazine capacity.

my A.K. is a romak 9-91, it has the humbhole stock and is, up to this point, un-modified.
so in not changing anything ( the rifle is all original- as it was imported) if I enlarge the magwell I am not breaking any laws: CORRECT??
Also I do NOT need to add any U.S. made parts if I enlarge the magwell to accept high cap mags: CORRECT??

sorrry to be a pain but I am as skittish as a cat on a hot tin roof about making mods to my A.K.  only to have the A.T.F. come beating on my  door and take all my guns have

Quoted: Quoted: OK, this is probably one of THE most asked questions: What are the parts that need to be replaced to be 922r compliant? (1) Frames, receivers, receiver castings, forgings or stampings (2) Barrels (3) Mounting blocks (trunions) (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 An gun can contain no more that 10 "imported" parts. The floorplate and follower count as one part each. Both handguards count as 1 part, the pistol grip counts as 1, as well as the stock is 1. By replacing the FCG with an American made version this counts as 3 parts replacement. Doesn't the AK have two trunnions?  A front and a rear.  Do they both count as a part, both count as one part or only one is considered a 922r part?  Also, does the sear and disconnector count as one part?  Does a semi-auto AK even have a sear?  Finally, there were some other items on a list I pulled from the BATF website such as a barrel extension, operating rod and trigger housing.  I know the AK doesn't have an operating rod but what do they mean by barrel extension and trigger housing?  If I get these answers cleared up then I think it will all finally make sense to me. I ordered a AK-74 parts kit from K-Var today and am very anxious to get this whole thing figured out so I can get her assembled.   I appreciate the time and help. ETA:  Here is the link to a thread I posted earlier today.  It contains the list of parts that was listed on the BATF website.

If you can believe the dictionary, the AK has only a front Trunnion.  The metal connector in the rear is called a TANG - noun.  A projection by which a tool, such as a chisel or knife, is attached to its handle or stock. Also called shank .  
A TOOL of the hunter and military man is his rifle.   The Tool is connected to the STOCK by the TANG.

this is only the case if i put a pistol grip correct

if i can find a more comfortable thumb hole stock to i still have to be compliant


thanks
munlin

Quoted: this is only the case if i put a pistol grip correct if i can find a more comfortable thumb hole stock to i still have to be compliant thanks munlin

I don't have a link to the letter (couldn't find it), but I've read a letter from the ATF in which their opinion was that aftermarket thumbhole stocks still counted as seperate pistol grips and buttstocks.

I would write a letter to the Firearms Technology Branch of the BATFE and detail your specific inquiry - i.e. model of rifle, and model of buttstock, sending pictures if possible.

Ok, heres one that has me stumped. I am trying to get enough parts to replace the thumbhole stock with a folding stock and pistol grip on my MAK-90 to be legal. If I buy a U.S. made magazine that counts as three parts, can I still shoot the rifle with foreign made magazines? Does the USA magazine have to allways be in the rifle? Or can I even OWN foreign made AK magazines? Is that considered attempt to destroy the universe or what? ALSO!, what about the gas tube that the upper handguard connects to, not considered a part? I hear that the chinese MAK-90 has a good trigger system in it. How do the american made triggers compare to them? Thanks for listening. -Turk182

Quoted: If I buy a U.S. made magazine that counts as three parts, can I still shoot the rifle with foreign made magazines?

That's a big negatory.  Placing the foriegn mag into the rifle is manufacture of a firearm that is in violation of 922(r).

Does the USA magazine have to allways be in the rifle?

Only when you're shooting it.  If you replaced, say, the buttstock and the pistol grip with US parts, and you used the US-made mag as your other three (MAK-90 only requires 5 parts replaced, as it only has 15 (no muzzle device)), it would have 15 parts with the mag in.  Only 10 would be foriegn.

Remove the mag, still only 10 foriegn parts.

Or can I even OWN foreign made AK magazines? Is that considered attempt to destroy the universe or what?

That's a grey area.  There's no law saying you can't.  Legally, it shouldn't be an issue.  It could be construed by the ATF as "constructive intent" - i.e. you planned to put the foriegn magazine in the rifle so that you could intentionally manufacture a firearm in violation of 922(r).

ALSO!, what about the gas tube that the upper handguard connects to, not considered a part?

Correct - see the list above - if it's not on that list, it's not considered a part per the ATF.

I hear that the chinese MAK-90 has a good trigger system in it. How do the american made triggers compare to them?

I'm sure some will argue with me, but it's six of one, half-a-dozen of the other.  To be sure, there are crappy FCG's out there.  FSE or G2 (always forget if they're the same) or RSA should all do you fine.  The Chinese FCG's in my MAK-90 and NHM-91 seem to work real well.  I'm only replacing them (with an RSA FCG, if you're curious) because I have an issue with using the magazine as your parts count, unless there's no other option.

For what it's worth, I do question the information in the second post about requiring the top and bottom of the forearm set to be considered "one" part.  I'm not the ATF, nor have I seen a letter from the ATF stating either side, but I don't consider the top piece to be a handguard - it's a heat guard, to be sure, but you don't hold it when firing.  The lower piece is the true handguard.

Now, again, with that said - I've only ever seen them sold as the pair, so I wouldn't go out of my way to find JUST the lower handguard.  On all the stuff I've converted or had converted, if the forearm is a conversion piece, both the lower and the upper gas tube section gets replaced.

AWESOME! Thank you. I think these rules are perhaps the gayest of any rules ever created in the history of firearms. I dont see how wooden handguards made in Europe are going to send me to jail but ones made in the US wont. WTF?!?!?!? I dont understand people with authority sometimes. Power corrupts, abosule power corrupts absolutly. Anyways how hard is the trigger to install. Ok heres some shit I am wondering about. If I replace my handguard with a US made folding stock, or replace any foreign parts with us made parts, am I still allowed to keep my old handguard (or foreign made parts) or will it be a grey line like the magazines. Having to throw out a perfectly good part that came with my rifle is idiotic if you ask me. I refuse to throw out parts for risk of being called a wtich or heretic or whatever else the 922r bullshit kangaroo court  says. Fuck it, ill buy a US magazine and tell them to kiss my ass. I am in the military and my job is to work on weapons systems made with a shit load of foreign made parts. Fuck it!

Quoted: Anyways how hard is the trigger to install.

It's not too hard - the Shepherd's Crook is a pain in the butt, but if you examine it closely prior to disassembly, it's not that horrible.

Ok heres some shit I am wondering about. If I replace my handguard with a US made folding stock, or replace any foreign parts with us made parts, am I still allowed to keep my old handguard (or foreign made parts) or will it be a grey line like the magazines. Having to throw out a perfectly good part that came with my rifle is idiotic if you ask me.

I agree wholeheartedly, it is stupid.

Again, I'll mention that it *COULD* be considered constructive intent, but that the ATF has never hammered an "end-user" (that this board knows of) on a 922(r) violation.

If I were going to keep said parts, I'd probably store them well away from my rifles, say, at a storage unit or something.

Now, personally, on my Maadi MISR or MAK-90 conversion, if anyone on this board wanted the parts, I'd give them to that person, otherwise, I'd probably chuck them - they have zero use or value to me, and I'll never put them back on my rifles, so why keep them around?

I noticed the parts on my MAK are numbered the same (serial number?) The Bolt, Bolt carrier and reciever all have the same 5 digit number on them. These are perfectly good parts. I refuse to live in fear caused by a lack of intelligence from our lawmakers. This is just to unbelievable to me. Do you know of anywhere that sells good, reliable, reasonably priced US made steel mags for the AK? Thanks for all your help man. -Turk182

I don't think any US manufacturer makes steel mags.

ProMag makes polymer mags very similar to the Bulgarian Waffle Mags - www.promagindustries.com/ak47.asp.

Personally, I'd replace the following parts on your MAK-90:

Furniture - Buttstock, Pistol Grip, Forearm - 3 parts.  

Ironwood Designs makes a version for the MAK-90 for $88 - www.ironwooddesigns.com/2aprod/1zAKproduct.html

K-Var sells a synthetic set that can be mated to a MAK-90 easily for $84.99 for black, $89.99 for OD Green or Plum - www.k-var.com/product.asp?0=270&1=271&3=92 (Link goes to black version)

Fire Control Group - Hammer, Trigger, Disconnector - 3 parts.

G2 (Gordon Technologies) FCG from Tapco is $44.99, and comes with an RSA retainer bracket that replaces the Shephard's Crook - www.tapco.com/product_information.asp?number=OFFER0650&back=yes&dept=190&last=13 (Without the retainer, it's $39.99)

RSA FCG from Red Star Arms (www.redstararms.com) is usually about $85.00.  It's fully adjustable for pull and all kinds of stuff, and you can usually find it pretty cheap from Sportsman's Guide or other sources - post in the General AK Discussion for a source.

So - with that said.

Utilizing the cheapest of the parts above, you could 922(r) convert your AK for $125, and then buy a buttload of Chinese or East German steel mags for $6-$10.  $125 + $100 (for 10 mags) = $225

Or, you could spend $28 per ProMag, get 10 mags, and spend $280.

It's cheaper, and less hassle, to buy the furniture and FCG, slap the stuff in, and not have to worry about US mags - and it gives you a much wider variety of mags you can use - like drums.

Nobody makes a US drum, as of yet.

Dumping a 75rd drum is pretty fun stuff!

No disrespect to you, I guess that I am just venting, BUT how is it possible to replace a reliable steel magazine with a US counter part if there is none to replace it with? What does the law say about replacement parts that lower the reliability, safety and effectiveness of a weapon? What does the law say about replacement US parts that do not exist? Sweet jeebus. Today is one of those days where I am ashamed of our law system. I think I am going to spend the extra buck-a-zoids and go with the trigger setup. Thank you for all of your assistance Kythri.

I recently purchased a WASR-10 (with pistol grip, not thumbhole stock) and was told that the magazine that came with it was U.S. made and that only U.S.-made magazines could be used with it in order to maintain the proper parts count.  Is this true?

If so, I understand that other parts can be substituted in order to maintain the proper parts count and use foreign magazines.  Very well, but how do I identify U.S.-made parts and foreign-made parts (such as stock, etc.)?

I apologize if this has already been answered or if it is a moronic question.   I did do a search but could not find the answer.

Thanks,
-KW

Quoted: I recently purchased a WASR-10 (with pistol grip, not thumbhole stock) and was told that the magazine that came with it was U.S. made and that only U.S.-made magazines could be used with it in order to maintain the proper parts count.  Is this true?

If they only used 2-3 other US-made parts in the rifle, it's true.

Unless your magazine was plastic and made by "Pro-Mag", it's probably not a US-made magazine.

If so, I understand that other parts can be substituted in order to maintain the proper parts count and use foreign magazines.  Very well, but how do I identify U.S.-made parts and foreign-made parts (such as stock, etc.)?

By the receipt for the purchase of said parts, or by a little "US" engraved or stamped on the parts.

What's the probability of the parts being marked "U.S." ?

I checked the stock last night and there was no marking.  The mag was steel with only a circled "C" mark on the bottom.

-KW

Quoted: I noticed the parts on my MAK are numbered the same (serial number?) The Bolt, Bolt carrier and reciever all have the same 5 digit number on them. These are perfectly good parts. I refuse to live in fear caused by a lack of intelligence from our lawmakers. This is just to unbelievable to me. Do you know of anywhere that sells good, reliable, reasonably priced US made steel mags for the AK? Thanks for all your help man. -Turk182

Mak 90 Conversion ---

Get a USA Mag follower plate
        USA Mag end plate
        source - Midwestarmory.com   Cost about $3.00

Get new USA make furniture   butt stock, foregrip and pistol grip    about $90.00.

5 parts replaced.  

The Mak-90 I BELIEVE only has 15 countable parts per batf regulations.

Replace 5 and suddenly you have a 922 compliant weapon. - or so I believe.

Total cost to convert from a politically correct sporting rifle to and EVIL Wicked Weapon perfered by criminals and hateful gun nut types - about $100.00.    

Quoted: Unless your magazine was plastic and made by "Pro-Mag", it's probably not a US-made magazine.

There is a company now, National Magazine, that is making steel AK mags in the USA. They suck though from my experience so far, but are dirt cheap.

Anyway, i'm going through this parts bit too. I just got an SLR-95 and want to put a regular buttstock on it. That is two parts there, then a trigger group is 3 more. Then I should be set, right, even if i use foreign mags? I'd be right at 10 imported parts by my count. Milled recievers don't have trunnions, yes? I assume the brake on the end of the SLR counts as one. If somebody could confirm my count i'd appreciate it, but as I see it I can get by replacing just the FCG and thumbhole stock with a US made pistol grip/buttstock and be legal with an SLR-95.

thanks!

Oh one more thing, I like the bulgarian waffle mags, do these take the same floor plate as all other mags? If so I may swap the one off my wobbly National mag with it and have one more part.

Does a side scope mount count as a part? And how does the mag floor plate thing work, can you put a us floor plate on any mag and be able to use it?

does reciever cover count as 1 part?

Just wondering, has anyone ever heard of someone getting busted for not having enough US parts?

Quoted: does reciever cover count as 1 part?

Yes

Quoted: Just wondering, has anyone ever heard of someone getting busted for not having enough US parts?

As I understand it, No