[expeditionx]

arizcowboy,

I was keeping the info on this page as a database to use from time to time.
All semi auto shotguns made from 11 listed countable foreign parts would be subject to import law.
This just means they cant have a bayonette, magazine over 5 rounds, folding/telescoping stock, or any other ATF disapproved feature.
The exception is if it was in the country prior to a 1990 cutoff date and no further additions were made since then.
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ATF letters:

Dear Sir or Madam:

I am writing to request clarification regarding ATF’s current legal stance regarding the use of detachable magazines in SKS Carbines. I own several SKS Carbines and desire to know as accurately as possible the legal status of these. In general, your previous responses have been helpful. Despite these, I am still left with unanswered questions regarding 18 U.S.C. 922(r):

The “Federal Firearms Regulations Reference Guide” (2000 edition) contains a list of characteristics which would identify a semiautomatic rifle as not suitable under the sporting purposes test for importation in 18 U.S.C. 925(d). These characteristics include “the ability to accept a detachable magazine, folding/telescoping stocks, separate pistol grips, ability to accept a bayonet, flash suppressors, bipods, grenade launchers, and night sights. The reference guide then mentions that any of these military features, other than the ability to accept a detachable magazine, would make a semiautomatic assault rifle non-importable. Thus in and of itself a detachable magazine is not a prohibited feature.

Further, a letter from ATF was printed in the NRA magazine, American Rifleman, May 1994, p.44. That letter provided guidance to SKS owners and has since achieved wide circulation. It commented that the “following modifications of an SKS type rifle would not be a violation of Section 922(r)…replace the fixed magazine with a detachable magazine. This modification may be done provided the bayonet mount is completely removed from the rifle.” Thus, it would appear that as late as 1994, detachable magazines were allowed on SKS Carbines if no other military features were present.

I further understand that in April 1998, the “Department of The Treasury Study on the Suitability of Modified Semiautomatic Rifles” resulted “in a finding that the ability to accept a detachable large capacity magazine originally designed and produced for a military assault weapon should be added to the list of disqualifying military configuration features identified in 1989.” The study referred to such magazines as “large capacity military magazines”, and later seemingly enumerated these as “a detachable large capacity magazine (e.g., more than 10 rounds) that was originally designed and produced for one of the following military assault rifles: AK47, FN-FAL, HK91 or 93, SIG SG550, or Uzi.” It is notable that magazines for SKS carbines are not mentioned.

The type of detachable magazine available for use in standard SKS Carbines is the “duckbill-style”. “Duckbill-style” magazines are not in any way interchangeable with the AK47-style magazines with which some Chinese SKS Carbines were imported. To the best of my knowledge, the “duckbill-style” magazine has never been in military use in any nation. Thus despite the fact that these magazine are available in capacities greater than 10-rounds, it would seem that the “duckbill-style” magazine is not a “large capacity military magazine”

In view of the foregoing, I have two questions:

1) Is adding “duckbill-style” detachable magazine to a standard SKS Carbine which has no military features a violation of 18 U.S.C. 922(r)?

2) If this modification is a violation, why is this so? Please make reference to any additional material that would help to illuminate this matter, especially since the “duckbill-style” detachable magazine does not seem to be a LCMM.

I sincerely appreciate your efforts in responding to this letter.

LESchwartz


ATF wrote:

Dear LESchwartz

This refers to your letter to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), Firearms Technology Branch, dated September 24,2003, asking about the modification of an SKS rifle to permit acceptance of a detachable "duckbill-style" ammunition magazine.

Title 18, United States Code (U.S.C.), Chapter 44, Section 922(r), states, in part, that 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….”

Currently, SKS rifles capable of accepting a large capacity ammunition-feeding device are prohibited from importation. Therefore, modifying an SKS to accept a large capacity ammunition-feeding device would be a violation of 922 (r).

We thank you for your inquiry and trust the foregoing has been responsive.

Sincerely yours,

Sterling Nixon
Chief, Firearms Technology Branch