A stamped-receiver AK has 15 922(r) parts (16 if you have a muzzle brake -- see Note #6 below).
A milled-receiver AK has 14 922(r) parts (15 if you have a muzzle brake).
A Saiga hunting rifle has a stamped-receiver, no pistol grip and no muzzle brake (14 parts)
- Frames, receivers, receiver castings, forgings or stampings
- *Mounting blocks (front trunion on stamped-receiver AK)
- *Muzzle attachments
- Bolt carriers
- Gas pistons
- Pistol grips
- Forearm handguards (upper and lower together count as 1 part)
- Magazine body
The following US-made parts are readily available to substitute to acheive the required number of ten or less imported parts to be 922(r)-compliant:
- pistol grip
- upper and lower handguards (upper and lower together count as 1 part)
- muzzle brake
- gas piston
- Magazine body
NOTE #1: The upper and lower together count as 1 part. Here's the references from an ATF letter which used to be posted on the Soupbowl Enterprises web site: Page 1
, Page 2
& Page 3
. Page #2 contains the relevant text about the upper and lower together making up the "handguard" on an AK rifle. Both parts together constitute a single part for counting of 922(r) parts.
NOTE #2: On the AMD-65 & AMD-63, there is no upper handguard. However, the lower handguard and forward pistol grip together are one counted part. For more infomation see: AMD Info from ATF
NOTE #3: Caution should be used when using US-made followers, floorplates, or magazine bodies. The following quote was taken from an ATF letter which used to be posted on the Soupbowl Enterprises web site
: “However, if the modified rifle were possessed with an imported magazine that does not have a domestically manufactured follower a violation of § 922(r) would occur.”
NOTE #4: If you're building up a parts kit that came with a full-auto FCG, it needs to be replaced no matter what.
NOTE #5: Acording to ATF a thumbhole stock counts as two 922(r) parts
-- a buttstock and a pistol grip. For more infomation see: Saiga Drag Stock Letter from ATF
NOTE #6: The nut used to protect the muzzle threads is likely considered a "muzzle attachment" by ATF. This means the muzzle nut should be considered a "muzzle break".
NOTE #7: "Trunnion" is an old cannon term that refers to the cylindrical projections on either side of a cannon barrel that allows it to pivit. Only front "trunnion" fits this description of a barrel mounting block. The answer to question #2 in this letter
clearly states that the rear trunion is uncounted.
Disclaimer: I am not a lawyer. I am not a 922(r)-legal specialist. The above information is simply a summary of the consensus of AK-47 owners & builders of the 922(r) regulations as available by a search of the Net.