To stay compliant with Section 922(r), a semiautomatic rifle or any shotgun assembled from imported parts can contain no more than 10 imported components from a specific list of 20. If your build uses more than that, swap enough imported pieces for U.S.-made equivalents to bring the count to 10 or lower. The rule applies whether or not you hold a federal firearms license.1Bureau of Alcohol, Tobacco, Firearms, and Explosives. 27 CFR 478.39 – Assembly of Semiautomatic Rifles or Shotguns
Which Firearms the Rule Covers
Section 922(r) reaches two categories: semiautomatic rifles, and all shotguns, including pump-action and other manually operated designs.1Bureau of Alcohol, Tobacco, Firearms, and Explosives. 27 CFR 478.39 – Assembly of Semiautomatic Rifles or Shotguns The pump-action piece surprises people who assume only semi-auto shotguns qualify. Handguns and firearms built entirely from domestic components sit outside the rule.
The rule only bites if the assembled firearm is “identical to” one that could not be imported under the sporting-purposes test.2Office of the Law Revision Counsel. 18 USC 922 – Unlawful Acts In its 1989 study of semiautomatic rifle imports, the ATF identified eight “military configuration” features that block importation. Any one of them, other than the ability to accept a detachable magazine on its own, was enough to keep a rifle out:
- Folding or telescoping stock
- Separate pistol grip
- Bayonet mount
- Flash suppressor
- Bipod
- Grenade launcher
- Night sights
- Ability to accept a detachable magazine
If the firearm you are assembling has any of those features and uses imported parts, you almost certainly need to count parts.3Bureau of Alcohol, Tobacco, Firearms and Explosives. Import Firearms, Ammunition, and Defense Articles AK-pattern rifles built from foreign parts kits and imported tactical shotguns with pistol grips or folding stocks are the platforms that most often raise the issue.
The 20-Part List
Compliance runs off a specific list of 20 components. No more than 10 of them, as installed on the finished firearm, may be of foreign origin.1Bureau of Alcohol, Tobacco, Firearms, and Explosives. 27 CFR 478.39 – Assembly of Semiautomatic Rifles or Shotguns
- Frames, receivers, receiver castings, forgings, or stampings
- Barrels
- Barrel extensions
- Mounting blocks (trunnions)
- Muzzle attachments
- Bolts
- Bolt carriers
- Operating rods
- Gas pistons
- Trigger housings
- Triggers
- Hammers
- Sears
- Disconnectors
- Buttstocks
- Pistol grips
- Forearms or handguards
- Magazine bodies
- Followers
- Floorplates
Only parts actually present on the assembled firearm count. A gun without a pistol grip doesn’t count a pistol grip. That means different designs start with different totals, and some platforms are easier to bring into compliance than others.1Bureau of Alcohol, Tobacco, Firearms, and Explosives. 27 CFR 478.39 – Assembly of Semiautomatic Rifles or Shotguns
Getting to 10 or Fewer Imported Parts
Count the imported parts on the list that your firearm uses. If the total is more than 10, replace enough of them with U.S.-made equivalents to reach 10 or below. A typical AK-pattern rifle built from a foreign parts kit might use 15 or 16 of the listed components, so five or six substitutions are usually needed.
Some swaps do more work than others. A magazine counts as three separate parts (body, follower, and floorplate), so a U.S.-made magazine drops three imported parts in one move.1Bureau of Alcohol, Tobacco, Firearms, and Explosives. 27 CFR 478.39 – Assembly of Semiautomatic Rifles or Shotguns Domestic furniture (buttstock, pistol grip, handguard) removes three more. A domestic trigger group (trigger, hammer, disconnector, and sear) accounts for up to four. Between a domestic magazine and a domestic trigger group, you can drop seven imported parts without touching the barrel or receiver.
Documentation is the weak link. No federal registry tracks which parts in a given gun are domestic versus imported, and the parts themselves often carry no country-of-origin marking. Keep receipts from U.S. parts manufacturers. If a question ever arises, that paperwork is what shows the build is legal.
Assembly Is What’s Prohibited
The statute makes it unlawful “to assemble from imported parts” a non-sporting firearm.2Office of the Law Revision Counsel. 18 USC 922 – Unlawful Acts The act being punished is the assembly itself, not mere possession. In theory, buying a pre-assembled non-compliant firearm on the secondary market does not make the buyer the one who committed the 922(r) violation; the person who assembled it did.
That same language cuts the other way for modifications. Swapping a U.S.-made part for an imported one on an otherwise compliant rifle, and pushing the count above 10, can itself count as a new “assembly.” Any time you change parts on a firearm built from an imported platform, run the count again before you shoot it.
Penalties
A willful 922(r) violation is a federal felony carrying up to five years in prison, a fine, or both.4Office of the Law Revision Counsel. 18 USC 924 – Penalties “Willfully” carries weight in that provision. A prosecutor would have to show you knew what you were doing was illegal, not just that your parts count was off by mistake.
As a practical matter, 922(r) is one of the least-enforced pieces of federal firearms law. Standalone prosecutions of individual gun owners are essentially unheard of. When the charge does appear, it is usually stacked on other offenses during investigations of dealers, importers, or criminal enterprises, and ATF enforcement attention runs toward licensed manufacturers and importers who are already subject to inspection.
That is not a reason to ignore the rule. It is a federal felony on paper, and nothing prevents a prosecutor from adding it if you draw law-enforcement attention for another reason. For anyone building a rifle from an imported parts kit or modifying an imported shotgun with aftermarket components, a handful of U.S.-made compliance parts is cheap next to the risk.