Sks Modification

[ZACKROCK]

I have a 1952 Russian sks. I think It was purchased when the Brady Bill was in effect. Is it legal to put a 30 round clip in this thing and change the stock to a m4 style collapsible,composite stock? I dont want to break the law.

 

[jayd]

If it was imported as a curio and relic it has to stay stock
If you want to mod it you have to have a certain amount of parts installed that are stamped made in the USA

letters to and from the ATF

From this board

http://www.sksboards.com/

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ATF is saying that an SKS only has 14 parts, instead of the 17 parts we imagined. Note that the final list does not include a muzzle attachment, a second disconnector or an operating rod.

Larry

PS: For scans of the original letter, see: Page 1, Page 2, and Page 3. For scans of the followup response, see Follow up, Page 1.



Quote from: LESchwartz to ATF
March 2, 2007

To whom it may concern:

I currently own several fixed-magazine Chinese SKS Rifles and am contemplating various modifications. Some of the modifications contemplated are prohibited on semiautomatic rifles using more than 10 of the imported parts listed section 478.39(c). Therefore it is critical to correctly enumerate which of these parts are used in my SKS rifles.

In addition, a parts list purported to be from an ATF Field Office has recently appeared on a prominent Internet web site devoted to the SKS rifle. I am a moderator for this website, and I am concerned that this list appears to have at least one error.

I done extensive research, and have attempted to enumerate the section 478.39(c) parts found in my SKS Carbines:

(1) Frames, receivers, receiver castings, forgings or stampings
(2) Barrels
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnector
(15) Butt stocks
(17) Forearms, handguards
(18) Magazine bodies
(19) Followers

With reference to “(8) Operating rods” — The book “The Official SKS Manual” (translated by Maj. James F. Gebhardt) page 20, refers to the part in question as a “driving rod”. The book “The SKS Carbine — 2nd Ed.” (by Steve Kehaya and Joe Poyer) page 71, refers to the part in question as a “gas piston extension”. The book “The SKS—Type 45 Carbines” (by Duncan Long) also refers to this part as a “piston extension”. However, in many firearms, a metal rod that acts on the bolt carrier of a rifle and is not one in the same with the gas piston is called an “operating rod”. Thus, many vendors refer to this part of an SKS Carbine the “operating rod”. This part is omitted from the “Internet parts list” mentioned above.

With reference to “(14) Disconnector” — The book “The Official SKS Manual” (translated by Maj. James F. Gebhardt) refers to a particular part (page 20, Figure 33, part #6) as the disconnector. The book “The SKS Carbine — 2nd Ed” (by Steve Kehaya and Joe Poyer) refers to a different part (page 51, part #T6) as the disconnector. On the other hand, the book “The SKS—Type 45 Carbines” (by Duncan Long) refers to both of these parts (page 101, parts #49 & #50) as disconnectors.

In view of the foregoing, I have two very specific questions:

1. Which of the imported parts listed section 478.39(c) are present in Chinese SKS rifles?

2. Which part does ATF consider to be the disconnector in Chinese SKS rifles?

While it is not my desire to cause your office any unnecessary workload, given the potentially serious consequences of even inadvertent violations of Federal Firearms law, I am left with little alternative. I have been unable to locate clear answers to these questions despite extensive research. And thus, I sincerely appreciate your efforts in responding to this letter.

Sincerely,

LESchwartz




Quote from: ATF to LESchwartz
Dear LESchwartz:

This is in response to your letter of March 6, 2007, to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), Firearms Technology Branch (FTB), in which you ask the following questions:

1. Which of the imported parts listed in “section 478.39(c)” are present in Chinese SKS rifles?
2. Which part does ATF consider to be the disconnector in Chinese SKS rifles?

As background, the amended Gun Control Act of 1968 (GCA), 18 U.S.C. Section 922(r), states the following:

It shall be unlawful for airy 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... [U.S. Attorney General]

Also, 27 C.F.R. Section 478.39 states

“…(a) No person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph (c) of this section if the assembled firearm is prohibited from importation under section 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes.

(b) The provisions of this section shall not apply to:

(1) The assembly of 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 such rifle or shotgun for the purposes of testing or experimentation authorized by the Director under the provisions of [§478.151(formerly 178.151)]; or (3) The repair of any rifle or shotgun which had been imported into or assembled in the United States prior to November 30, 1990, or the replacement of any part of such firearm.

(c) For purposes of this section, the term imported parts [tabulated below] are.



(1) Frames, receivers, receiver castings, forgings, or castings.
(2) Barrels.
(3) Barrel extensions.
(4) Mounting blocks (trunnions).
(5) Muzzle attachments.
(6) Bolts.
(7) Bolt carriers.
(8) Operating rods.
(9) Gas pistons.
(10) Trigger housings.
(11) Triggers.
(12) Hammers.
(13) Sears.
(14) Disconnectors.
(15) Buttstocks.
(16) Pistol grips.
(17) Forearms, handguards.
(18) Magazine bodies.
(19) Followers.
(20) Floor plates.



Therefore, it is a violation of 18 U.S.C. § 922(r) to assemble such a rifle or shotgun from more than 10 of the imported parts specified in 27 CFR § 478.39. However, assembly of certain semiautomatic rifles or shotguns using 10 or fewer of these imported parts is not prohibited under this section. With respect to your inquiry regarding Chinese-made SKS carbines, please note that because this firearm was manufactured in China, all the parts used to assemble the rifle are considered imported per 922(r).

Further, please note that a Chinese-made SKS carbine, in its original military configuration, consists of the following parts derived from the list presented above:

1. Receiver.
2. Barrel.
3. Muzzle attachment.
4. Bolt.
5. Bolt carrier.
6. Gas piston.
7. Trigger housing.
8. Trigger.
9. Hammer.
10. Sear.
11. Disconnector.
12. Buttstock.
13. Forearm/handguard.
14. Magazine body.
15. Follower.

However, a Chinese-made SKS carbine, in its original military configuration, does not contain the following parts:

1. Barrel extension.
2. Mounting block (trunnion).
3. Operating rod.
4. Pistol grip.
5. Floorplate.

With respect to your question regarding whether the part located in the sight assembly is an operating rod or a piston extension, FTB does not consider this part to be an operating rod. Additionally, concerning the classification of the part that aligns the trigger bar with the sear, we consider this part to be a disconnector for 922(r) purposes.

We trust the foregoing has been responsive to your request.

Sincerely yours,

Richard Vasquez
Acting Chief, Firearms Technology Branch



Quote from: LESchwartz to ATF
May 9, 2007

To whom it may concern:

This is a follow up to your May 2, 2007 letter (903050:MRC 3311/2007-453) where you respond to questions regarding the number and identity of imported parts contained in Chinese SKS Carbines. Thank you for your response, the information was most helpful. However, I have one additional question:


Your list of parts contains a “Muzzle Attachment”. Unlike Yugoslavian SKS rifles that are equipped with grenade launchers, I am unaware of a part that would constitute a muzzle attachment on Chinese SKS carbines.

With regard to Chinese made SKS carbines in original military configuration, which part are you referring to as the muzzle attachment?


I sincerely appreciate your efforts in responding to this letter.

LESchwartz



Quote from: ATF to LESchwartz
Dear LESchwartz:

This is in response to your letter of May 9, 2007, to the Firearms Technology Branch (FTB), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), in which you inquired concerning which part FTB was referencing as a “muzzle attachment” in a previously written reply (refer to #3311/2007-452).

In fact, we incorrectly listed a muzzle attachment as an original part for a Chinese SKS carbine. We apologize for any confusion this error may have caused.

We trust the foregoing has been responsive to your request for a clarification.

Sincerely yours,

Richard Vasquez
Acting Chief, Firearms Technology Branch

 

[ZACKROCK]

Hey Jayd, this is chasing shadows from rocketmadness.com. Thanks for your response.

 

[ZACKROCK]

So according to this letter I can change the stock to m4 style and the clip?

 

[jayd]

Good to cya here

You prolly want to look more of this stuff up on the SKS site but as I understand it if you chnage 1 thing you would have to change and additional 9 items (total of 10) to American parts to be legal
Someone correct me if I am wrong please

Anyway, good luck