Good reference information.  Should be helpful looking for those getting into a new shotgun.

Wish I had this chart when I made my M4 compliant. Should be a sticky.

What about the M2 with a non-pistol grip stock (ie comfortech)?

Is the list 11 or 12 parts?

Could someone give me a quick rundown on what's up with this? Im new into shotguns but have been dealing with nfa stuff alot within the past few years, and I hvaemy heart set on a benelli m4 h2o.

I think it would be 12 because no gas piston. But I wonder since the M4 has two gas pistons, does 922r count it as two parts or one?

It is counted as one.

922(r) 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...

So basically, by "assembling" the shotgun using aftermarket parts, you have now come under the purview of 922(r) and in order to remain compliant with the law, must satisfy the requirement of having no more than 10 imported parts of the following 20:

(1) Frame/receiver
(2) Barrel
(3) Barrel extension
(4) Mounting blocks (trunions)
(5) Muzzle attachment
(6) Bolt
(7) Bolt carrier
(8) Operating rod
(9) Gas piston
(10) Trigger housing
(11) Trigger
(12) Hammer
(13) Sear
(14) Disconnector
(15) Butt stock
(16) Pistol grip (Counts only if separate from buttstock, so for the Benelli M3 they are not separate parts and count as one)
(17) Forearm/hand guard
(18) Magazine body (Magazine Tube)
(19) Follower
(20) Floorplate

Of those 20, only 13 really apply to the Benelli M4:

(1)   Receiver
(2)   Barrel
(3)   Bolt
(4)   Bolt carrier
(5)   Gas piston
(6)   Trigger housing
(7)   Trigger
(8)   Hammer
(9)   Disconnector
(10) Buttstock (with integral pistol grip)
(11)  Forearm/handguard (forend)
(12)  Magazine body
(13)  Follower

So in order to remain in compliance you need to replace enough parts, so that only 10 or fewer of those parts in that list are imported parts.  This is what the OPs chart references and breaks down for you.

wait, so does the magazine tube's count as 1 on these guns?
And I always thought the safety counted as 1, but it isn't on either list.

this is excellent and really really needs to be a sticky

It irritates me to no end that we have to deal with this insanity.

This chart should be accompanied by a large disclaimer. The information it contains comes from a very questionable and private ATF letter, not an official public statement from ATF.

The list shows only one gas piston while the M4 has two gas pistons. To suggest that you count only one is not based in anything ATF has said publicly and it violates common sense.

Follow this chart at your own risk guys.

So now you bring this list up... did anyone realize that a barrel extension is present on the M4, M2, m3, etc...? So wouldn't that be another part?



I am so confused with all this nonsense.

Pretty sure Mako stuff is made in Israel, and thus would not be a 922r part.

That's not a barrel extension by 922r standard, though even if it were, it's integral to the barrel and thus included as such. Similarly, Benelli factory terminology calls the entire bolt assembly a "bolt", though it clearly breaks down into a bolt and bolt carrier.

This is why these types of threads can be a bit dangerous. There is no official ATF position on the Benelli M4 as it pertains to 922r. Private letters, which this information is 100% based upon, are publicly non-binding to ATF. They can be and frequently are incorrect.  If you are the recipient of such a letter, feel free to follow its guidance, but everyone else is no protection.

It does, yes.  Changing out the magazine tube does count as a part IF you change it out with a US made tube.  The factory Benelli 7-shot tube is imported and therefore does not count.  Safety does not count from my understanding.

and neither does a new carrier?

This sucks. Ok, follower, easy and cheap. Extended Magazine tube, easy and functional.

The third piece for the M2 compliance? Trigger, hammer, disconnector, forearm or stock. All expensive and worthless, adding no real benefit to upgrade.  

I personally am going with the Geissele hammer. If nothing else, it's a known quality part.

It seems OOS everywhere and is listed as being for the M4 only. Are they the same?

I bought the three part package from Freedom Fighter along with the follower for a total of 4 parts.

It was a simple 15 minute job to swap out the parts.

Very silly we have to deal with this but a few bucks to CYA is simple enough.

It's for the Benelli M4 only, as far as I know.

It all depends on interpretation.

And since when was there a "standard" for the very vague guidelines of 922R (as per ATF website). Factory terminology holds very little salt as well, the ATF agents decision is what matters.

I am just saying, its a "barrel extension" with thread locker, locking lugs, and the ejector. We can say it is integral to the barrel, but clearly it can removed and replaced. This service part isn't even identified on the M4 Super 90 manual.


The aftermarket M4 hammer can fit the M1, M2, M3, Supernova, nova, etc....

I waited over a year for their M2 charging handle and just gave up. Good to see their FCG is good. Pretty pricey though. Does the trigger feel better now?

No clue, mine wouldn't work, lol.
FFT often has tolerance issues.

There are cheap US made copies of the Benelli handguard available from FFT which counts.  You could also change the buttstock unless you like the factory one.  On mine I went with:  Mesa Tactical Buttstock, CarrierComp Mag Tube, CarrierComp follower, and for good measure a 4th part, the Surefire M80 handguard.

Best bet is to replace as many parts as you reasonably can.

I have three Benelli M4's, and I have the following 922(r) compliance parts on all three;
carriercomp magazine tubes
carriercomp magazine follower
Geissele Hammer
FFT Disconnector
FFT Trigger
FFT Reproduction Handguards

This gives me a few parts over the accepted standard of 4 for the OEM collapsible stocks.