Quoted: From a BATF letter ruling in which the writer asked about having multiple short-barreled uppers while owning both an M16 (SBR would be in the same class) and a regular non-SBR AR-15 rifle:
Can you have several short barrel uppers (less than 16 inches) for the registered AR and still own semi-auto AR's?
The definition of a firearm in section 5845 of the NFA includes a rifle having a barrel or barrels of less than 16 inches in length. An individual possessing more than one short (less than 16 inches) barreled upper receiver for a registered AR15 machinegun along with one or more semiautomatic AR15 rifles would have under their possession of control an unregistered short barreled rifle, a violation of the NFA.
This ruling says that you can only possess a short-barreled upper if you have a registered weapon for it, and that you cannot own any extras if you also possess a non-SBR AR-15.
Just the barrel alone should not be a concern, as it is not readily convertible into an SBR. But I'd stay away from complete short-barreled uppers.
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This is wrong and has been retracted. This is also the same deal as the Thompson/Center ordeal.
If you have parts and all of them can be used in a legal configurations then you are fine.
As in this example, multiple shorty uppers can be used on the select fire lower. As long as the non NFA semi lower has a barrel of >16" you are fine.
This would not be legal if you had multiple shorty uppers and no >16" barrel for the non-NFA semi lower. As you now don't have a barrel that can be used legally with the non-NFA lower.
Another example is this:
I have two 10" pistol barrels for my T/C Contender
pistol. One is .22lr and one is .243 Win. I also have a T/C Contender
rifle in .30-06. Even though I have an extra pistol barrel, I am not in violation of SBR law, as I can use all barrels legally in some fashion.
If I where to put the .22lr 10" barrel on the T/C rifle frame, then I would be in trouble.