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Discussion Starter · #1 ·
The Vepr IV RPK rifle has five US parts; hammer, trigger, disconnector, pistol grip and muzzle brake. Technically it needs six since it's a stamped receiver. Now 922r only applies to the builder, not the owner but I do try make sure all my stuff is compliant in case I ever want to sell it or run with original magazines. My thoughts. The piston itself is welded in place in two sections. Now technically if a muzzle device is blind pinned or welded in place onto a barrel, the muzzle device no longer counts as a seperate part for 922r. Now applying that logic, I think that a welded in piston would be the same, no longer a seperate part because just like a muzzle device- it to is welded in place and is now permanently attached to the carrier. It's not like you can just drift out a pin and pull it apart like on a standard piston, this would require drilling out the welds, then breaking the welds to get the piston free. So given this, I think it is safe to assume the same. Maybe some else might chime in with their thoughts on the matter. Simply, I don't see how BATFE could categorize tack welded muzzle devices as not being a separate part and not apply the same logic to pistons.


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Discussion Starter · #3 ·
Don't they come with a US mag? 3 more parts.
That little mag only counts when it's in the rifle. Not if you are running the rifle with a factory imported mag- which is my point. You might not even need another US part.
 

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You do have a point. Piston and carrier are now 1 part, same as muzzle and welded device. You can run the muzzle with exposed threads or shoot the rifle without a mag and be legal. It's only when you add a device that it comes into play. It's total parts count, no more than 10 imported parts. In that vein, You conceivably could weld the pin that holds the gas piston so it's not removable. It would keep it's designed in floppiness but still be one part. All my rebuilds take advantage of US followers and floorplates in original mag bodies. Using the concept of a 1 piece carrier and piston makes any AK compliant with a US trigger group and compliant mag.
 

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If it were me I'd be busting the piston loose and pinning in a Tapco to avoid mechanical issues
 

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I'd probably change the piston so I could use one more Russian part like a pistol grip or flash hider. You don't really see it, plus there are several sources for quality solid head pattern pistons made here in the US. It's not a hard item to replace, even at home.
 

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Discussion Starter · #8 ·
6 parts are easy.

3x Trigger group
Flash hider (CNC warrior copy)
Mag floor plate (Arsenal USA is a perfect mechanical and cosmetic fit on the 45rd mag)
Pistol grip (either factory or Arsenal USA, or "Ronin" black Maadi grip)

Done. I would avoid changing out gas piston if at all possible.


I don't do the magazine parts for any AK's. I never have. To easy for someone to run the rifle with the wrong magazine.

I see five parts which is all it needs since the piston is welded to the carrier; hammer, trigger, sear, pistol grip, and muzzle brake. Technically 922r applies to the manufacturer, not us anyway.


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Discussion Starter · #9 ·
I'd probably change the piston so I could use one more Russian part like a pistol grip or flash hider. You don't really see it, plus there are several sources for quality solid head pattern pistons made here in the US. It's not a hard item to replace, even at home.

The piston is punch welded in by the factory so technically, it's no longer a separate part of the carrier not that has been "permanently" attached to the carrier.



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The permanently attached issue has been one of the debated topics like 922r applying to title II weapons etc.

922r does not note any exemption for permanence or threads etc. of a muzzle device. Elsewhere in the code the reference to determining barrel length is a separate issue., not related to 922r.
922r also lists barrel extensions separately.
The ATF decision letter indicates a permanent muzzle attachment is still applicable to Section 18 USC and whether it is a flash suppressor or can launch a grenade. So that must be taken into account as to whether it is countable part for 922r etc.
Whether a permanently attached piston or muzzle device is counted or not counted is debatable.?????????????????

 

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I'd probably change the piston so I could use one more Russian part like a pistol grip or flash hider. You don't really see it, plus there are several sources for quality solid head pattern pistons made here in the US. It's not a hard item to replace, even at home.
The gas piston is a nice, factory installed unit... The pin/weld is done very well... So replacing it, and actually having it look as nice, is going to be a huge PITA.

Not to mention, the CNC Warrior unit is EXACTLY like a Russian RPK74 flash hider, other then the finish (paint vs just oxide). I have compared the two side by side. Its also a hell of allot cheaper then Kvars Russian unit.


I don't do the magazine parts for any AK's. I never have. To easy for someone to run the rifle with the wrong magazine.

I see five parts which is all it needs since the piston is welded to the carrier; hammer, trigger, sear, pistol grip, and muzzle brake. Technically 922r applies to the manufacturer, not us anyway.


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It was a 7.62x39 or 5.45 gun, I would agree with you. But its 5.56, and takes its own unique magazine. Too easy to change out a mag floor plate vs a gas piston, etc.
 

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Discussion Starter · #13 ·
The permanently attached issue has been one of the debated topics like 922r applying to title II weapons etc.

922r does not note any exemption for permanence or threads etc. of a muzzle device. Elsewhere in the code the reference to determining barrel length is a separate issue., not related to 922r.
922r also lists barrel extensions separately.
The ATF decision letter indicates a permanent muzzle attachment is still applicable to Section 18 USC and whether it is a flash suppressor or can launch a grenade. So that must be taken into account as to whether it is countable part for 922r etc.
Whether a permanently attached piston or muzzle device is counted or not counted is debatable.?????????????????


It doesn't say that once a part is permanently attached that it counts as a seperate part, it becomes a permanent extension to the barrel or bolt carrier and thus counts as one less part. You would then subtract that part from the ten parts or less. They are saying that a flash hider even permanently attached still counts as a feature of being an assault rifle- not for 922r. I know I'm onto something with this.

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It doesn't say that once a part is permanently attached that it counts as a seperate part, it becomes a permanent extension to the barrel or bolt carrier and thus counts as one less part. You would then subtract that part from the ten parts or less. They are saying that a flash hider even permanently attached still counts as a feature of being an assault rifle- not for 922r. I know I'm onto something with this.

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Title 18 is about importability and by extension to 922r. AFAIK.
The permanent extension to the barrel deals with length under NFA Title II. Not 922r.
 

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Discussion Starter · #15 · (Edited)
Title 18 is about importability and by extension to 922r. AFAIK.
The permanent extension to the barrel deals with length under NFA Title II. Not 922r.
First and foremost, 922r only pertains to the BUILDER, MANUFACTURER OR IMPORTER- not the individual.

However, once you permanently attach a muzzle device it no longer is counted as a separate part.

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First and foremost, 922r only pertains to the BUILDER, MANUFACTURER OR IMPORTER- not the individual.

However, once you permanently attach a muzzle device it no longer is counted as a separate part. Barrel length aside, permanently attached means just what it says, now one part.


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If you are attaching a permanent muzzle device you are building/assembling.
Extensions are noted separately from muzzle devices in 922er regulations.
The decision letter above seems to indicate differently than you assertion. Believe what you will.
 

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Discussion Starter · #17 · (Edited)
If you are attaching a permanent muzzle device you are building/assembling.
Extensions are noted separately from muzzle devices in 922er regulations.
The decision letter above seems to indicate differently than you assertion. Believe what you will.

Read the letter again and show me where it says a muzzle device permanently attached, i.e. welded, still counts as a separate part for 922r. Says that a flash hider (permanently attached or not) still counts as a feature for 921A or 18 USC whatever that is- but nothing about 922r. Once a part is permanently attached, not just pinned but welded according to their specs of 1100 degree solder or better then it is permanently attached- according to them, not me.


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Read the letter again and show me where it says a muzzle device permanently attached, i.e. welded, still counts as a separate part for 922r. Says that a flash hider (permanently attached or not) still counts as a feature for 921A or 18 USC whatever that is- but nothing about 922r. Once a part is permanently attached, not just pinned but welded according to their specs of 1100 degree solder or better then it is permanently attached- according to them, not me.


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Title 18USC us what dictates the weapons and assembly that must comply with 922r because they are not sporting arms. That is the over riding legality.

Permanent attachment relates to barrel length. Parts types/origins relate to 922r. Barrel extensions are different than flash suppressors.
 

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Discussion Starter · #19 · (Edited)
Title 18USC us what dictates the weapons and assembly that must comply with 922r because they are not sporting arms. That is the over riding legality.

Permanent attachment relates to barrel length. Parts types/origins relate to 922r. Barrel extensions are different than flash suppressors.
Features, i.e. folding stocks, pistol grips, flash hiders is one thing for sporting purposes but individual parts count per 922r is another since they list parts separately. The reason the milled AK only requires 5 US parts is because the "trunnion" is part of the receiver, all one piece. Same would apply to a re-welded milled receiver that now again, through welding- all becomes one piece. However the same would apply here, by their very own definition, a part is considered "permanently attached" once you weld it into place. Well, once it is "permanently attached" it no longer is counted as a separate part just as a trunnion being permanently part of the milled receiver is not considered a separate part. Would be nice to maybe get it down to having some internals and that's it.


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Features, i.e. folding stocks, pistol grips, flash hiders is one thing for sporting purposes but individual parts count per 922r is another since they list parts separately. The reason the milled AK only requires 5 US parts is because the "trunnion" is part of the receiver, all one piece. Same would apply to a re-welded milled receiver that now again, through welding- all becomes one piece. However the same would apply here, by their very own definition, a part is considered "permanently attached" once you weld it into place. Well, once it is "permanently attached" it no longer is counted as a separate part just as a trunnion being permanently part of the milled receiver is not considered a separate part. Would be nice to maybe get it down to having some internals and that's it.


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The same question can be asked in the juxtapose. Where does it state a welded part is not countable. The decision letter states the opposite and determines a flash suppressor remains a recognized part under 18 USC.
But following your logic., vs the ATF or USC code. If I weld vs pin a series of AK parts., like the barrel to trunnion., trunnion to receiver., gas piston to carrier they become conjoined single parts and not counted individually . I do not think that is accurate.
Funny how Century does weld the gas pistons for expediency but still use US pistons. I'll let it go., not worth any further discussion. Do as you wish but read Title 18 USC about assembly and parts.
No big deal as there is seemingly little enforcement of these regs and various interpretations.
Agree to disagree. If there is a decision letter or other info determining that a foreign part., eg., flash suppressor that is permanently attached is not countable or is considered part of the barrel as a combined single part., I would welcome that as a good thing.
 
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