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NHM91 "RPK" U.S. Parts count?

2K views 15 replies 5 participants last post by  eodinert 
#1 ·
I am intrested in buying a NHM91 "RPK" 47 that is at a local gunshop. It has an East German stock set with a pistol grip sold with it. I asked them how many U.S. parts were in it, and they said they didn't know for sure "if any." So, my question is; How many U.S. parts have to be in NHM91 converted to a pistol grip configuration? "It has a threaded muzzle." Is it 6?

EDIT: I was told by 2 different dealers that since it was manufactured BEFORE the A.W.B. took effect that it can legally be in pistol grip configuration without any U.S. parts. Sound right?
 
#2 ·
It's probably a 92 or 93 import, like mine, which means it came in after the ban on chinese imports. This means you do have to play the parts game. With the threaded barrel, you will need 6 US parts. Mine has the muzzle nut tacked on, so it doesn't count, my other 5 parts are gas piston, FCG (3), and US grip. If they "don't know" or say they "don't think it does" they are either stupid or lying.
 
#3 ·
The weapon was legal at the time without US parts... at what point did it become required for it to have US parts retrofitted?

Not trying to be difficult, but think about it... if it had a threaded barrel, it was already 'evil'.

The US parts thing only became an issue when folks were looking for a backdoor around the Bush ban, around 95 or 96.
 
#4 ·
Thanks for the info man.

I have bought and sold several guns through these guys, and I've known them for a long time. The RPK was a trade-in several years ago, and it remained in the personal collection of one of the store members for many years.

I'd be getting a really good price on it. :neutral: When was the ban on Chinese imports? Is there anyway to find out when it was imported?

I'm just going to buy it and not worry about it. :smile: Any advice?
 
#5 ·
The problem with asking that question is that there really isn't an answer; only opinions. The law is too convoluted.

According to the ATF, a 'thumbhole' stock is nonsporting, just like a pistol grip. So, your weapon, with a thumbhole stock, is just as 'nonsporting' as it would be with a pistol grip. (that re-interpretation was a futile attempt to stop the flow of AKs coming into the country with 'sporting' thumbhole stocks).

It's a catch 22.

The really sad part is that I had a chance to work with some ATF firearms enforcement agents a few years back (during the clinton ban). I was all excited to ask them my questions.

NONE of them had any idea what the law was. They said 'I just send it to tech branch, and let them rule on it'. I could go on, but I won't.

Bottom line, you need to find your comfort zone, and go with it. For you, maybe that's a bunch of US parts. Or, maybe not. You will not get a concrete answer from the ATF.

Do your homework, then go for it.
 
#8 ·
solution_zero said:
What does everyone else do?
I don't think anybody is going to jump in here and say 'I don't give a hoot about the US parts count', but I would imagine that there are more than a few people who have given up out of frustration.

How do you determine where a part is made? There is no requirement to mark them.

If I take a piece of honduran mohogany, and carve a stock out of it, is it US made?

If I take a $20 stock made out of honduran mohogany, and spend 50 hours re-shaping, sanding and finishing, is it US made?

If I take a $5 disconector, bead blast it, park it, dura coat it, and sell it for $20 bucks, is it US made?

This stuff has all been established in US trade law, and I'm pretty sure if we were making cars every one of my examples would be considered US made...

They just make the stuff up as they go. You can only make so much sense out of it.
 
#10 ·
If the weapon came in after section 922(r) took place in 1989, it does not matter if it has a rubber bayonet. If it is semi auto, has a pistol grip and takes hi-cap mags it can NOT have more than 10 imported parts. Period. End of story. The 10 parts has nothing to do with the 1994 AWB, it has to do with Sec. 922(r).
 
#12 ·
I talked to the dealer today and he told me "There is nothing illegal about that gun."

I was told to read 922(r), and that it only pertains to builds.

922(r) It shall be unlawful for any person to assemble from imported parts any semiautomatic rifle or any shotgun which is identical to any rifle or shotgun prohibited from importation under section 925 (d)(3) of this chapter as not being particularly suitable for or readily adaptable to sporting purposes except that this subsection shall not apply to?
(1) the assembly of any such rifle or shotgun for sale or distribution by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
(2) the assembly of any such rifle or shotgun for the purposes of testing or experimentation authorized by the Attorney General.


Can anyone point me to any document that may help concerning thumbhole stock to pistol grip conversion legalities?

EDIT: He brought up the example of the WASR imports. They have no U.S. parts, can accept high capacity mags, and have a pistol grip. Intresting.....
 
#13 ·
The NHM91 is a Post-Ban (post '89) import. It came equipped with a "compliant" thumbhole stock set made likely from country of origin with the exception of Boyd's and Bishop U.S. made counterparts which have little bearing on parts count unless you utilize the handguards which only account for 1 U.S. componant.

These laws all get confusing, and I know of much specific reference to post-ban Chinese guns in relation to the definition of so-called "assault weapons" is muddy turf. Sure we know thousands of 'non-compliant' guns are in existance/circulation. JMHO, but a 'good deal' would be a much 'better deal' if a post-ban Chicom was U.S. parts compliant. It's anybody's choice but with 'compliance parts' readily available there's not much of a defense for failure to follow the letter of the law.

"EDIT: I was told by 2 different dealers that since it was manufactured BEFORE the A.W.B. took effect that it can legally be in pistol grip configuration without any U.S. parts. Sound right?"

Sounds wrong. I purchased early Romanian thumbhole stock rifles with 100% Romanian internals (1997). To legally add pistol grip, military configuration stocksets and such, Section 922 still applies. And no matter how much I desire a legal configuration with the 'proper' red Romanian pistol grip I have to make a concession at the forend or buttstock with something along the lines of Ironwood products.

As for FFL holders and issues of legality when it comes down to a sale? Nevermind. I don't expect the local cops to be legal experts because they're not. Gun dealers are just that, I think it would be a safe bet most don't really care so long as the firearm is a solid semi and they don't believe they're passing a major violation off to the buyer. If they've been in the biz since the 90's or even the 80's, they know darn well federal laws were passed based on cosmetic differences and comparing a MAK90 to a SAR or WASR (as similar they might be) is apples to oranges.

Not trying to be a stick in the mud nor an expert. I've waded these waters before having bought a 'non-compliant' variety of rifle that should have legally fallen into a 'grandfather clause' situation that would deem compliance moot. I added a U.S. stock and guts... Fantastic shooter, before and after.

Peace of mind vs. piece of mind. :cool:
 
#14 ·
Thanks for all the info WildWes. Its nice to hear advice from those who once were in the same boat.

I found out the WASR's that accept highcaps are modified by the boys at Century with U.S. Trigger, Disconnector, Hammer, Piston, and Pistol grip.

As for now I'm putting a Romanian thumbhole stock on it until I buy another G2 Trigger group and an American RPK Flashhider.
 
#15 ·
If you have a non-pistol grip stock and no threaded muzzle or bayo lug... but then ADD one of those features... you are MANUFACTURING a weapon that 922(r) applies to. You do not have to make the RECIEVER, you just have to MODIFY the gun.
 
#16 ·
Q-gunner2 said:
If you have a non-pistol grip stock and no threaded muzzle or bayo lug... but then ADD one of those features... you are MANUFACTURING a weapon that 922(r) applies to. You do not have to make the RECIEVER, you just have to MODIFY the gun.
But remember, ATF declared butthole stocks evil for the purposes of importation.. that butthole equipped gun is already EVIL, especially if the muzzle nut is not properly attached, that's extra evilness, right there. A varitable cornucopia of evil.

Yes, I am trying to muddy the water.
 
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