I've got a German fullsize mp5 kit I'm going to build and sbr.  I prefer not to use magazines for compliance parts.  What's everyone using for 922r parts?

Since it is a parts kit the receiver will be one unless you start with like a Turkish finished receiver.

Cocking handle is another simple one. Same with the front handguard.

In my sp5k I also used us trigger, hammer, and sears. I used a B&T barrel so I couldn't use that as a part that counted and wanted to stay away from us made parts in the firing system since my sp5k came with nice new german parts. Since I'm guessing you are rolling a flat I'd think the Trunion would be a good choice. If you did that with the trigger box parts and small stuff like the cocking handle you'd hit the 6 parts needed pretty quick.

If your lower isn't ambi you can get the trigger box or the pistol grip as us made too.

Source a PTR trigger box and FCG, can also use the grip housing and pistol grip if you need more US parts.

Need a lot more details. What's the origin of the receiver? Barrel? Trunnion? You want to use an A2 stock, A3 stock, or B&T stock? SEF or pictogram lower?

Use the parts calculator online, look at HKParts, and figure out your priorities. There was exactly one way for me to accomplish 922(r) compliance with my gun set up the way I desired.

US receiver for sure.  Foreign magazines for sure.  All else is up in the air.  Kit I believe is all German.  SEF lower.  I'd like to keep the HK bolt and carrier.  

Thanks for the replies, gives me some ideas of what others are doing.

In that case, definitely swap the stock, forearm, and cocking handle. Those are the low hanging fruit.

Then your best bet is hammer / trigger / sear. Alternatively, the trigger pack and housing could be swapped out as well...But personally I would avoid that route unless you want to use a B&T stock and need another U.S. part.

To the best of my knowledge, 922r rules applies to firearms BEFORE importation into the USA or DURING domestic manufacturing and/or the conversions of imported "sporting" types of firearms into what the ATF calls "non-sporting" firearms.  The "end user," the purchaser/owner can put any other parts onto his/her own firearm without violating U.S. Law, specifically 922r.

That's my understanding, so if I "was" going to manufacture a firearm, I would used the easiest U.S. Made parts to swap out later, like a U.S. Made magazine, handguard, buttstock, pistol grip and charging handle... Once the firearm was fully completed, swap out any of those parts for parts I really wanted.

I know many want to play it safe, which I don't blame anybody for doing since I would do the same.  Plus, nobody wants to deal with some dick-headed "Barney Fife" from some small town Sheriff's office, questioning the legality of your firearm(s) since in his limited mind, he knows all the ins and outs of every law within the United States, when in fact, he most likely barely knows his own State laws...  Even worse, a "Range Master" with a god complex, who "claims" to have a buddy that's an agent with the ATF, FBI, CIA, DHS, NSA and so on, as he writes down your vehicle's license plate on his spiffy little note pad.

On a serious note, I cannot ever see a local U.S. Attorney's Office ever taking on a simple 922r violation case and presenting to a federal grand jury for prosecution... Unless there was some "other stuff" that you're doing, causing them, the government, to REALLY want you at any cost.  I don't even think an ATF agent would even present a case involving just a 922r violation to the AUSA's office, unless there was something more serious to go with it, like somebody manufacturing a fully automatic firearm or several unregistered SBRs and/or being involved in some other serious criminal activities.

Would I ever test this? Probably not.  I'm simply throwing this out there for a thought. And by no means am I an attorney, acting like an attorney or giving out any 100% factual information... Yes, this is my disclaimer!!

Low chances of prosecution don't talk me into potentially breaking the law.  I'll be making sure I have enough compliance parts as long as I own the gun, I enjoy sleeping in my own bed.

You only need "a" magazine with compliance parts. Other mags could be completely foreign. ATF does not consider changing mags to be "assembling" per their letter.

Yeah I'd rather avoid that.

This, just don't leave a foreign mag in the gun when stored.  Just leave the magwell empty.  Maybe get the franklin armory binary kit for H&Ks and the PTR lower that has only two positions.   A cocking handle.   Whats the point of a German kit if you are going to replace a bunch of parts with crap.

That would be in direct conflict with the law itself which counts 3 magazine parts in the total count.

You wouldn't happen to have a link to that letter, would you? I'd like to read the full context of that.

It is worth saying if you are low on your parts you can always just put us made baseplates on the real hk mags. Takes one part away from the rifle and you still get what makes the German mags better.

http://www.falfiles.com/forums/showthread.php?t=261731

Looks like I remembered wrong. 

Sorry. 

Apparently if you rely on a mag for compliance, and then swap in a completely foreign mag, you have committed a 922(r) violation.

I'm not sure what happens if you acquire a non-compliant firearm which already has a completely foreign mag. I guess you could continue using foreign mags, since you wouldn't affect the parts count by replacing the mag?

Technically you could probably get away with one US mag, as long as it was first.

922(r) is a law against manufacture, not against possession. If the SBR is made with a US mag it should be good to go. Using a different mag later wouldn't be remanufacturing

Except when you insert the foreign mag you are essentially assembling it with a new combination of noncompliant parts.

That would be an argument a court would have to decide.

Put it this way, if a licensed manufacturer built a SBR and included a US mag to count for 922(r) and someone buys it. Later on down the road they use a HK mag in it. Do you really expect any court to believe they just manufactured a new weapon with a 922(r) violation?

If you're claiming that they legally assembled it with 6 US parts including those three then yes, I do believe that the court could go that way.

You can't credibly claim that it only applies once.

Let's say you buy a MKE pistol that already has 3 US parts. You SBR it and make it compliant by inserting a US mag. If you then change to a HK mag, explain to me your argument on how inserting the US mag constitutes assembly and inserting the HK mag doesn't.

I've got what I needed from this thread.  I wasn't looking for opinions on what was or was not right about 922r but what parts people used.  I appreciate the help I got, now time to build.

If you are already in court arguing it is not, you are already phucked.

LOL, While I agree, and I tend to stick to the "safest bet" and keeping myself out of the "grey area"; I highly doubt ATF would ever go after a single 922(r) violation without any other issues going on as well.

With as poorly as it's written, they would likely have too much to lose pressing the issue.