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922(r) Worksheet for MKA 1919 builds and Various Clones

See also: Sporting vs Non-Sporting Firearms, ATF Correspondence Archive on the Akdal MKA 1919

The United States has a lovely bit of import law, Title 18 USC 922(r), which prevents most of the more interesting rifle designs from being directly imported into the US. The import regulations are commonly referred to as "922(r)" in gun circles.

In order to legally build a non-sporting rifle out of a parts kit (or modify a 'sporting' rifle to include 'non-sporting' features), no more than 10 imported parts may remain in the final product. This is generally done by replacing foreign-made parts with domestically-built parts.

It's worth knowing that the MKA 1919 has 14 ATF-counted parts - 6 do not apply to these shotguns. So, for folks who insist on only half-understanding 922(r), the MKA 1919 needs 4 US-made parts to be compliant.

This information is derived from a scanned ATF letter I found on Gunsumer Reports.

Note that the pistol grip and buttstock are apparently joined with the receiver in the MKA 1919, and that's why they are counted as one part.

Checklist for 922(r) compliance on MKA 1919 builds

Please note that the as-imported configurations are compliant. This checklist becomes important whenever you wish to replace original parts on an imported weapon, or if you are building one from the ground up.
N/A Barrel extensions
Mounting block (front trunion)
N/A Muzzle attachment
Bolt carrier
Operating rods (cocking handle)
Gas piston
N/A Trigger housing
N/A Sear
N/A Buttstock
N/A Pistol grip
Forearm, handguard
Magazine body


-- SeanNewton - 10 Feb 2009-- SeanNewton - 03 Jul 2012

Topic revision: r1 - 03 Jul 2012 - SeanNewton
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