A member of saiga-12.com found this BATF letter posted on the internet:
It shows the parts count for several different types of semi-auto firearms. In this letter the ATF has listed the parts that correspond to each specific type of firearm that the person questioned them about.
One of the listed SA firearms was the Saiga shotgun. The BATF lists 13 total for the Saiga shotgun. This means you only have to change 3 parts to US parts to be legal in regards to 922(r)....
Pass on the info
I was pondering this the other day... 922(r) applies to assembling firearms that would be restricted from importation, and those are, of course, those that are determined to not be "particularly suitable for, or readily adaptable for sporting purposes". Nothing new for most guns, of course - make sure your parts count is good an keep moving.
However, the verbage that allows shotguns w/ a bore over .5" is pretty much the same. Any gun w/ a bore over .5" is a DD, "other than a shotgun or a shotgun shell which the Secretary finds is generally recognized as particularly suitable for sporting purposes". So.... if a shotgun w/ a bore over .5" is determined to not be importable in a certain configuration (because it is found to be "non-sporting"), would that not make it a DD by default in that configuration, regardless of parts count?
I know that SG's have only been named DD's by make/model so far, but I believe that was because the AWB enacted shortly thereafter made anything similiar illegal anyway. Since it looks like the AWB will indeed sunset, I expect this to come up again - as people start their conversions and the antis try to grab at whatever remaining they can.
No, different things. A shotgun being declared "non-sporting" directly from the Secretary of the Treasury by specific make and model is what would constitute a DD. A shotgun that is "not suitable or readily-adaptable to sporting purposes" is a determination made by ATF Import Branch for the disapproval for importing a particular firearm. Import Branch makes this determination on their own based on generic, subjective criteria established by the SECTREAS. See the difference? Treasury Secretary is who reclassified the USAS-12 et al to DDs, not the AG.
Adding folding stocks and pistol grips to detachable mag Saiga shotguns will certainly raise the bar, could put these guns on the SECTREAS radar, but until then it's perfectly legal to do after the AWB expires and after the parts count is adjusted. Have at it.