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922(r) Worksheet for Saiga Shotguns

Also, see the main 922(r) page
Also, see the Saiga rifle 922(r) page
Also, see the ATF Letters on Saiga parts count

This chart is for Saiga Shotguns ONLY. The Rifle is different and has its own chart!

The United States has a lovely bit of import law, which prevents most of the more interesting rifle designs from being directly imported into the US. It prevents the direct importation of AK-series rifles, and has ended up creating a market for demilitarized parts kits.

However, the "sporterized" Saiga rifles are allowed to be imported because, although based on an AK action, they do not have pistol grips or the capacity to accept an AK-47 magazine. However, because plenty of folks ardently desire a Russian-made AK, they buy Saigas and convert them into AK-47's. But because they have a different initial parts count than the AK-47, folks get confused and start thinking that it's somehow easier to convert a Saiga to be 922(r) compliant than a normal AK-47. This is not the case, particularly since folks typically want to keep the Russian-made receiver, which requires them to get into changing out the gas piston or other such silliness. At any rate, it is not necessary to alter a Saiga for 922(r) compliance unless it has ceased to be a sporting rifle. Adding a pistol grip or folding stock to one absolutely triggers 922(r). However, it is not certain that converting one to accept AK-47 magazines automatically triggers a need for 922(r) compliance. One other special consideration for the Saiga is that if you're doing a conversion which utilizes a pistol grip, the pistol grip becomes a counted 922(r) part. But in the base Saiga, there is no pistol grip so it doesn't count.

Please be aware that ATF considers any shotgun with more than 5 rounds of magazine capacity to be "non-sporting". If you choose to use the 10rd or 20rd magazines on your Saiga-12, you must be 922(r) compliant first!

At any rate, the sum of all the check boxes in the form below will automatically add themselves up as you click and unclick them. This allows you to easily consider how you can ensure that your shotgun is as 922(r) compliant as it needs to be.

NOTE: The default is now for the boxes to start off checked, and you un-check them for each compliance part. When viewing the forum threads which link to this page, I was seeing FAR too many people who weren't reading the instructions, and were only selecting their compliance parts instead of the imported parts as intended! So now all the boxes start off checked and you de-select your compliance parts. Hopefully this will be safer for people who don't/can't/won't read instructions!

The list of parts which 922(r) counts is:

  Part Available Notes
Receiver Yes Typically, folks hold onto the original Saiga receiver.
Barrel No  
  Barrel extensions N/A  
Mounting block (front trunion) No Only the front trunion matters.
Muzzle attachment Yes Be careful here. ATF could reclassify the thread protector as a muzzle device.
Bolt No  
Bolt carrier No  
Operating rods (cocking handle) ??? On a Saiga rifle, this would be the gas piston.
Gas piston Yes For shotguns, see addendum below.
  Trigger housing N/A  
Trigger Yes  
Hammer Yes  
  Sear N/A Combined with the trigger in AK designs
Disconnector Yes  
Buttstock Yes  
Pistol grip Yes Not installed in stock configuration.
Forearm, handguard Yes  
Magazine body Yes See below
Follower Yes See below
Floorplate Yes See below


Compliance count script by tearsinraine


  • On AK's and on Saiga rifles, the steel shaft extending off of the bolt carrier is the gas piston. However, in Saiga shotguns the "puck-shaped" disc located in the gas block is considered the gas piston and the same part which would be called a piston on any other Kalashnikov variant is considered an operating rod. This means Saiga shotguns have one more counted part than their rifle counterparts. For clarification, see the letters on the subject. Thanks to kwikrnu for informing me of this update.
  • For Saiga shotguns, because the barrel is threaded and a thread protector is fitted on over it, the ATF may classify that thread protector as a muzzle device. If asked, they would almost certainly rule chokes or anything other than the thread protector to be a muzzle device.
  • Parts which are not named in 922(r) DO NOT COUNT towards your compliance parts count!
  • As per an ATF letter located here, magazine parts are not subject to constructive possession. If you need US-made magazine parts in order to reach 10 or fewer imported parts, then you don't have to replace parts on all of your magazines - only the ones which you intend to use with this rifle. The easiest solution is to only own US-made magazines, of course, but this is not always feasible, particularly if no US-made magazines are available for the weapon in question or, for legal reasons, you can't buy domestic full-capacity magazines to replace your old imported magazines.
  • Saigas's don't have trigger housings, apparently, within the meaning of 922(r).
  • Sears are combined into the trigger. The few-moving-parts design of the AK-47 contributes to its importability.
  • Barrel extensions would only be there if you welded one on, and that'd make it a domestic part.

Disclaimer: There are no lawyers on this site. At least, none who are writing authoritatively as such. Section 922(r) is clear enough for anyone to read, but if you can't be bothered to read it for yourself, neither of us will take responsibility for your not doing so. This page is presented as a helpful refresher / worksheet, not as a replacement for your personal reading of the law.

-- SeanNewton - 08 Dec 2011

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Topic revision: r2 - 11 May 2012 - SeanNewton
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