• ODT Gun Show & Swap Meet - May 4, 2024! - Click here for info

Any 922(r) "experts" out there?

nope. I have never seen even one documented case of anyone being charged with violating 922R. Its like one of those dumb laws that are never enforced by anyone ever
After my first wife's suicide in 97 I got a surprise visit by two ATF agents. They had a list of everything that was supposed to be in my home. They never did tell me what they were looking for or why they were there. They just looked at everything I had wrote some things in a notebook and left. Point here is that I was scared ****less when they walked in because I had removed the hideous thumb hole stocks from my Mak90 and my Century FAL and replaced them with the original style stocks and pistol grips. But neither agent gave them a second look.
 
After my first wife's suicide in 97 I got a surprise visit by two ATF agents. They had a list of everything that was supposed to be in my home. They never did tell me what they were looking for or why they were there. They just looked at everything I had wrote some things in a notebook and left. Point here is that I was scared ****less when they walked in because I had removed the hideous thumb hole stocks from my Mak90 and my Century FAL and replaced them with the original style stocks and pistol grips. But neither agent gave them a second look.
Sorry to hear that :-(
 
I've always wondered how they are going to prove where parts came from if push came to shove.

Take the forearm for example. I have several Berettas (same company as Benelli) and none of the forearms are marked as to origin. Some have orig. buttstocks, some not. I've never seen those parts marked on a domestic shotgun. So if you say the buttstock is of domestic origin, who is to say it's not.

Agrees, I follow this type stuff pretty closely, and have never seen it be an issue in any way.

Sort of like Ayoob's advice about not using handloads for self defense.
 
Oh when US madentriggers are not marked Made in USA. I replaced US Arsenal triggers with ALG, and, AFAIk, neither was marked made in USA.
 
I was "that guy" who sent an email to ATF to get a response. I was shocked when they responded within one day, though I thought the triggers were the same between the M4 and SNT. It doesn't list a sear for the M4, but does on the SNT:

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 Supernova 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.





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.


Further, you asked: How many of the above-listed parts does a Benelli Supernova shotgun contain?



We will respond below by listing specific Benelli shotguns. Please note that although each of the Benelli shotguns described in our answers incorporate a functional “barrel extension,” it is permanently attached as an integral part of the barrel at the time of initial manufacture. For this reason, the Benelli shotguns listed below do not incorporate a barrel extension for 922(r) purposes.


Answer re the Benelli M1/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. Trigger housing.

6. Trigger.

7. Hammer.

8. Disconnector.

9. Buttstock.

10. Forearm(s).

11. Magazine body.

12. Follower.




With regard to the fixed pistol-grip stock of the Benelli M1/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.”


We caution, however, that the Benelli folding shotgun 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.”



Answer re the Benelli M2/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. Trigger housing.

6. Trigger.

7. Hammer.

8. Disconnector.

9. Buttstock.

10. Forearm(s).

11. Magazine body.

12. Follower.




With regard to the fixed pistol-grip stock of the Benelli M2/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.”


Ans. re the Benelli M3/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. Trigger housing.

6. Trigger.

7. Hammer.

8. Disconnector.

9. Buttstock.

10. Forearm(s).

11. Magazine body.

12. Follower.




Concerning the fixed pistol-grip stock of the Benelli M3/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.”



Ans. re 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.”


Ans. re the Benelli Nova shotgun: This contains the following parts from the above list:




  1. Receiver.
  2. Barrel.
  3. Bolt.
  4. Bolt carrier.
  5. Trigger housing.
  6. Trigger.
  7. Hammer.
  8. Sear.
  9. Disconnector.
  10. Forearm(s).
  11. Magazine body.
  12. Follower.


Although the Benelli Nova incorporates a functional “buttstock,” it is molded as an integral part of the receiver. Since a single component cannot be counted as two separate items under 922(r), the Benelli Nova shotgun does not incorporate a buttstock for 922(r) purposes.


Ans. re the Benelli SuperNova 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. Trigger housing.

6. Trigger.

7. Hammer.

8. Sear.

9. Disconnector.

10. Buttstock.

11. Forearm(s).

12. Magazine body.

13. Follower.



With regard to the fixed pistol-grip stock of the Benelli SuperNova 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.” Please note, however, that the Benelli SuperNova 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.”


You must replace at least 3 of the above mentioned parts with U.S. made parts in order to comply with 922(r).


We thank you for your inquiry and trust that the foregoing has been responsive.
 
Back
Top Bottom