snakehorse95 Posted January 31, 2011 Share Posted January 31, 2011 I know this topic has been beat to death, but I'm still on the fence about making modifications to my Benelli. I have a 18.5" M2 Tactical with pistol grip that I want to use for three gun. I'd like to run a mag extension on it, but have heard that it would no longer be 922r compliant. I've talked to several companies and they say just run the tube you'll be fine, but I've talked to other people and companies they all say that they are illegal. Any help on this subject would be helpful because at this point my head is spinning from trying to read into 922r compliance. Link to comment Share on other sites More sharing options...
Jesse Tischauser Posted February 6, 2011 Share Posted February 6, 2011 (edited) I am not sure what you are asking about your mag extension tube? Is that the California pistol grip statute deal? Edited February 6, 2011 by jtischauser Link to comment Share on other sites More sharing options...
snakehorse95 Posted February 7, 2011 Author Share Posted February 7, 2011 It was my understanding that according to stay in compliance with 922r the shotgun must stay in it's original importation configuration. Once you go to add an extension onto the magazine tube taking the shotgun past the 5 round limit you now need to meet 922r compliance by having only so many imported parts from the list BATF has. I was just curious what anyone knew about this and if anybody made parts here in the U.S. to make it 922r compliant. Link to comment Share on other sites More sharing options...
Mark R Posted February 7, 2011 Share Posted February 7, 2011 I think that the 922r compliance has to do with building a rifle or shotgun with foreign parts to complete a gun build. since the Benelli is an already built manufactured gun, I don't think 922r applies. And since the magazine extension is an American made part (if you use a Nordic components tube), still not an issue. Get the +5 extension to put on it and you will get 8+1 rounds inside since the original M2 magazine holds 3. Link to comment Share on other sites More sharing options...
Jadeslade Posted February 9, 2011 Share Posted February 9, 2011 Benelli no longer sells their own mag tube extensions in the US. DMW makes them here. Assault weapon ban law related. Non-issue. If the gun is imported, and you don't buy it off the back of a truck at Kennedy airport, it is legal. Depending on state of course. Link to comment Share on other sites More sharing options...
mpeltier Posted February 9, 2011 Share Posted February 9, 2011 Benelli no longer sells their own mag tube extensions in the US. DMW makes them here. Assault weapon ban law related. Non-issue. If the gun is imported, and you don't buy it off the back of a truck at Kennedy airport, it is legal. Depending on state of course. Do you have or can you point me to a letter from the ATF with this info? There seems to be a ton of information (dis-informatin?) about 922r compliance. It referances importable shotgun configurations as a basis for what you must replace (10 listed, american made parts) to make the shotgun leagal. If the shotgun does not have those 10 American made parts, and has the un-importable features as contained in 922r, it would be in violation of 922r, I have seen no distinction made as to wheather this applies to the importer or the owner, which implies it to anybody. I have heard there are letters from the ATF that suggest however that they are not looking for anyone a the range in violation of 922r, but that if someone were to use such a shotgun in the commision of a crime it could be a charge added to the list. Disclaimer: I am not a lawyer, this is my opinion only based on reaserch I have done. Do your own research and come to your own conclusion. Link to comment Share on other sites More sharing options...
snakehorse95 Posted February 9, 2011 Author Share Posted February 9, 2011 (edited) 922r compliance states that you can only have 10 imported parts off the ATF's parts list. You can use however many american made parts to get to the magic number ten, but they have to be parts from their list of 20. I've heard that they aren't looking for people making these mods unless they are used in committing a crime but I myself don't like the idea of doing any prison time. I've also heard people say that since it was able to be imported in that configuration then once here in the United States it's ok to modify as long as U.S. made parts are involved. My only concern about the validity of that would return to the siaga 12. In its imported configuration it is totally legal. Once you go and put on the pistol grip stock though you need to start replacing parts to get to the 922r magic numbers. I get kinda lost when reading about all this so I brought it here to these forums hoping someone with more knowledge on the subject then myself would step up and possibly give me a more definitive answer. I was also hoping maybe some other people would know of american made parts that could get me to the point of being at the magic number 10. I hate to think that I spent all this money on a Benelli shotgun and then I have to end up spending big bucks to try and make it legal for three gunning by replacing the stock, and forend grip or sending it off to Salient Arms and dropping another grand just so I can go out once a month to compete. I think with an aftermarket magazine tube, follower, and maybe one or two more parts, those of us with the M2 tactical would fall into the magic number of only 10 imported parts and would be legal to have however many shells we want. Edited February 9, 2011 by snakehorse95 Link to comment Share on other sites More sharing options...
mpeltier Posted February 9, 2011 Share Posted February 9, 2011 (edited) nothing to add. Edited February 9, 2011 by mpeltier Link to comment Share on other sites More sharing options...
Jadeslade Posted February 12, 2011 Share Posted February 12, 2011 Benelli no longer sells their own mag tube extensions in the US. DMW makes them here. Assault weapon ban law related. Non-issue. If the gun is imported, and you don't buy it off the back of a truck at Kennedy airport, it is legal. Depending on state of course. Do you have or can you point me to a letter from the ATF with this info? There seems to be a ton of information (dis-informatin?) about 922r compliance. It referances importable shotgun configurations as a basis for what you must replace (10 listed, american made parts) to make the shotgun leagal. If the shotgun does not have those 10 American made parts, and has the un-importable features as contained in 922r, it would be in violation of 922r, I have seen no distinction made as to wheather this applies to the importer or the owner, which implies it to anybody. I have heard there are letters from the ATF that suggest however that they are not looking for anyone a the range in violation of 922r, but that if someone were to use such a shotgun in the commision of a crime it could be a charge added to the list. Disclaimer: I am not a lawyer, this is my opinion only based on reaserch I have done. Do your own research and come to your own conclusion. Tom Knapp uses 10 rd magazines on his Benellis. Has had a lot of exposure-enough for ATF to see. He is, however, using it in a sporting manner. As we all do. There are at least a hundred posts about adding extended magazine tubes to Benelli shotguns in this forum. I am sure that in a test case, it could be proven that IPSC is a sport and so is USPSA. This is a good reason to keep competition guns and general use guns separate. As long as your gun is used for sporting purposes, I would not worry. This is getting to be a dead horse. Saigas are not Benellis. Moot. Link to comment Share on other sites More sharing options...
mpeltier Posted February 12, 2011 Share Posted February 12, 2011 Benelli no longer sells their own mag tube extensions in the US. DMW makes them here. Assault weapon ban law related. Non-issue. If the gun is imported, and you don't buy it off the back of a truck at Kennedy airport, it is legal. Depending on state of course. Do you have or can you point me to a letter from the ATF with this info? There seems to be a ton of information (dis-informatin?) about 922r compliance. It referances importable shotgun configurations as a basis for what you must replace (10 listed, american made parts) to make the shotgun leagal. If the shotgun does not have those 10 American made parts, and has the un-importable features as contained in 922r, it would be in violation of 922r, I have seen no distinction made as to wheather this applies to the importer or the owner, which implies it to anybody. I have heard there are letters from the ATF that suggest however that they are not looking for anyone a the range in violation of 922r, but that if someone were to use such a shotgun in the commision of a crime it could be a charge added to the list. Disclaimer: I am not a lawyer, this is my opinion only based on reaserch I have done. Do your own research and come to your own conclusion. Tom Knapp uses 10 rd magazines on his Benellis. Has had a lot of exposure-enough for ATF to see. He is, however, using it in a sporting manner. As we all do. There are at least a hundred posts about adding extended magazine tubes to Benelli shotguns in this forum. I am sure that in a test case, it could be proven that IPSC is a sport and so is USPSA. This is a good reason to keep competition guns and general use guns separate. As long as your gun is used for sporting purposes, I would not worry. This is getting to be a dead horse. Saigas are not Benellis. Moot. Yeah I know. I think we are saying the same thing, and have drawn the same conclusion. I was just hoping you had found something concrete with the "Its Legal" statement. Link to comment Share on other sites More sharing options...
snakehorse95 Posted February 13, 2011 Author Share Posted February 13, 2011 Yes I understand that alot of the top competitors use benelli shotguns with magazine extensions. But I would also like to know how they are getting away with it. If it's a salient arms benelli I think that since they have modified so many parts (i.e. kinda of now american parts) they are meeting compliance. Another way around it would be who are these guys out there shooting for? Are they or the people sponsering them holding a type 7 FFL which would allow them to bypass the whole 922r completely. I understand that shooting three gun would most likely not draw any attention to me and my shotgun even with an extension on it and ATF is only looking for people out commiting crimes with these evil features, but I would rather not risk taking a chance with that. Prison I don't think would suit me. Just kinda looking for some direction to go with this. Once I get my letter reguarding this back from ATF I'll post a copy for every one. Link to comment Share on other sites More sharing options...
Jadeslade Posted February 13, 2011 Share Posted February 13, 2011 Yes I understand that alot of the top competitors use benelli shotguns with magazine extensions. But I would also like to know how they are getting away with it. If it's a salient arms benelli I think that since they have modified so many parts (i.e. kinda of now american parts) they are meeting compliance. Another way around it would be who are these guys out there shooting for? Are they or the people sponsering them holding a type 7 FFL which would allow them to bypass the whole 922r completely. I understand that shooting three gun would most likely not draw any attention to me and my shotgun even with an extension on it and ATF is only looking for people out commiting crimes with these evil features, but I would rather not risk taking a chance with that. Prison I don't think would suit me. Just kinda looking for some direction to go with this. Once I get my letter reguarding this back from ATF I'll post a copy for every one. Sometimes we shouldn't ask questions we don't know the answer to. Why don't you use a Mossberg or Remington? Link to comment Share on other sites More sharing options...
00bullitt Posted February 14, 2011 Share Posted February 14, 2011 Why is it that 922r always gets so blown out of proportion? In the scheme of things....it doesn't even affect us. Link to comment Share on other sites More sharing options...
Mark R Posted February 14, 2011 Share Posted February 14, 2011 Why is it that 922r always gets so blown out of proportion? In the scheme of things....it doesn't even affect us. And if you aren't building it, why worry. 922r is on the books to prevent people from building illegal guns from illegal parts...not modifying already deemed legal guns...or am I missing something? Link to comment Share on other sites More sharing options...
chainring Posted February 14, 2011 Share Posted February 14, 2011 Yes I understand that alot of the top competitors use benelli shotguns with magazine extensions. But I would also like to know how they are getting away with it. If it's a salient arms benelli I think that since they have modified so many parts (i.e. kinda of now american parts) they are meeting compliance. Another way around it would be who are these guys out there shooting for? Are they or the people sponsering them holding a type 7 FFL which would allow them to bypass the whole 922r completely. I understand that shooting three gun would most likely not draw any attention to me and my shotgun even with an extension on it and ATF is only looking for people out commiting crimes with these evil features, but I would rather not risk taking a chance with that. Prison I don't think would suit me. Just kinda looking for some direction to go with this. Once I get my letter reguarding this back from ATF I'll post a copy for every one. Ever heard of the GemTax? Raise up off of us. Now is NOT a good time to be rattling the ATF cage. Link to comment Share on other sites More sharing options...
snakehorse95 Posted February 14, 2011 Author Share Posted February 14, 2011 (edited) 922r doesn't just apply to building firearms. It also applies to modifying firearms. And I'm not sure how I can be seen as "rattling" ATF's cage. I simply sent them a letter inquiring about what I need to do to maintain 922r compliance if I want to add to the magazine capacity. I started this thread thinking that maybe someone else here might have already have gone through all this and have an answer so that I wouldn't have to wait for an answer from ATF. And the reason not a remmington or a mossberg is because I got this shotgun basically brand new for half the MSRP. Edited February 14, 2011 by snakehorse95 Link to comment Share on other sites More sharing options...
00bullitt Posted February 14, 2011 Share Posted February 14, 2011 922r applies to assembling a semi automatic rifle or shotgun from imported parts which is identical from any rifle or shotgun that is prohibited from importation. Benelli's need not even worry here to even go any further and prove sporting purpose. Link to comment Share on other sites More sharing options...
snakehorse95 Posted March 24, 2011 Author Share Posted March 24, 2011 (edited) Just got a reply from the ATF concerning modifying a Benelli M2 tactical with pistol grip. Now keep in mind this only applies to pistol grip since the gun control act of 1968 only applies to semi auto shotguns with at least two of the following features 1: folding or telescoping stock 2: pistol grip 3. fixed magazine capacity in excess of 5 rounds 4. detachable magazine. Here is the gist of the letter the ATF sent me. This is in reference to your correspondence to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), Firearms Technology Branch (FTB), concerning the application of the Gun Control Act, 18 U.S.C. 922®, to your planned modification of a Benelli M2 shotgun. As you may know, 27 CFR 478.39 is the implementing regulation for 922 ®. This regulation specifies that a rifle or shotgun may bot be assembled from more that 10 of the following 20 imported parts listed below. 1. Frame or receiver.* 2. Barrels. * 3. Barrel Extensions. 4. Mounting blocks (trunnions). 5. Muzzle Attachment. 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. Magazine followers.* 20. Floorplates. As you know not every firearm will consist of all of the above-listed parts. We have indicated with an asterisk (*), those items from the list which comprise the M2. If you reassemble you M2 into a non-importable configuration, you must replace a total of at least three such components with U.S.-made parts. Also FTB recommends that you check with your local law enforcement agencies regarding any State laws or local ordinances that might also apply to the configuration of your modified M2 since some State laws are more stringent than Federal statutes. It would appear to me that I can either try and find three of the listed parts that are made in U.S.A., or I can remove the pistol grip stock and install a monte carlo style stock and I'm no longer bound by 922® because I therefore only have one of the evil features. It doesn't matter if you are building or modifying. It all has to do with taking the firearm out of importable configuration. Just a quick little note, I am not a lawyer and this is just my 2 cents on how this all comes into play. Edited March 24, 2011 by snakehorse95 Link to comment Share on other sites More sharing options...
Mark R Posted March 24, 2011 Share Posted March 24, 2011 Good info to know. Since the M2 Field that comes with the Comfort-tech stock does not contain any of the "Evil" items, modifying it does not make it applicable/eligible to the 922r requirement. Link to comment Share on other sites More sharing options...
Long Range Posted March 27, 2011 Share Posted March 27, 2011 Just got a reply from the ATF concerning modifying a Benelli M2 tactical with pistol grip. Now keep in mind this only applies to pistol grip since the gun control act of 1968 only applies to semi auto shotguns with at least two of the following features 1: folding or telescoping stock 2: pistol grip 3. fixed magazine capacity in excess of 5 rounds 4. detachable magazine. Here is the gist of the letter the ATF sent me. This is in reference to your correspondence to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), Firearms Technology Branch (FTB), concerning the application of the Gun Control Act, 18 U.S.C. 922®, to your planned modification of a Benelli M2 shotgun. As you may know, 27 CFR 478.39 is the implementing regulation for 922 ®. This regulation specifies that a rifle or shotgun may bot be assembled from more that 10 of the following 20 imported parts listed below. 1. Frame or receiver.* 2. Barrels. * 3. Barrel Extensions. 4. Mounting blocks (trunnions). 5. Muzzle Attachment. 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. Magazine followers.* 20. Floorplates. As you know not every firearm will consist of all of the above-listed parts. We have indicated with an asterisk (*), those items from the list which comprise the M2. If you reassemble you M2 into a non-importable configuration, you must replace a total of at least three such components with U.S.-made parts. Also FTB recommends that you check with your local law enforcement agencies regarding any State laws or local ordinances that might also apply to the configuration of your modified M2 since some State laws are more stringent than Federal statutes. It would appear to me that I can either try and find three of the listed parts that are made in U.S.A., or I can remove the pistol grip stock and install a monte carlo style stock and I'm no longer bound by 922® because I therefore only have one of the evil features. It doesn't matter if you are building or modifying. It all has to do with taking the firearm out of importable configuration. Just a quick little note, I am not a lawyer and this is just my 2 cents on how this all comes into play. Back in the 1990s in California when HK still imported Benellis we came to the same conclusion: non-pistol grip stock meant hi-cap magazine extension ok, pistol grip stock meant factory +2 extension ok (it was then imported that way). Kurt M. and others don't prefer the pistol grip stock for multiple reasons. FYI. Good luck Link to comment Share on other sites More sharing options...
CDRGlock Posted May 15, 2013 Share Posted May 15, 2013 I'm still waiting on the Mesa Tactical sidesaddle/rail. It has the regular grip, not the pistol grip. This has the following: Dave's Metal Works mag extension, tube clamp, extended bolt release Limbsaver 10401 GG&G quick release sling mounts GG&G Mag follower, 922r compliant Freedom Fighter Tactical, 922r compliant forend Vickers two point sling Based upon what I've read here, I only have to change two parts. Link to comment Share on other sites More sharing options...
CDRGlock Posted May 26, 2013 Share Posted May 26, 2013 Benelli M2 Tactical VMW extension (7+1), Tube Clamp (not installed on pics), Extended Bolt release GG&G Mag follower, Quick release front and back sling mounts Vickers Blue Force 2 point sling Mesa Tactical 6 shell carrier and mount Limbsaver 10401 Freedom Fighter Tactical Forend Link to comment Share on other sites More sharing options...
HeinrichDerLowe Posted June 8, 2013 Share Posted June 8, 2013 Does everyone use a 2 point shotgun sling for 3 gun? I'm tempted to buy just the rear sling mount and either use a single point sling or just a loop of paracord. Any thoughts? Link to comment Share on other sites More sharing options...
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