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  1. #1
    Gunco Regular shotgunner's Avatar
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    Default 922r question

    Does the Romanian PSL fall under the 922r laws with only a 10rd mag?
    If it needs to be 922r compliant, what is the parts count for this gun?

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    Gunco Veteran Markp's Avatar
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    Quote Originally Posted by shotgunner View Post
    Does the Romanian PSL fall under the 922r laws with only a 10rd mag?
    If it needs to be 922r compliant, what is the parts count for this gun?

    That's a great question... the answer is maybe.

    So what can you do to avoid 922(r)?

    You would need to consider the following criteria.
    CRITERIA ELEMENTS 1 - 5

    1. Does the weapon have a military configuration?

    a. ability to accept a detachable magazine?
    b. folding/telescoping stock?
    c. pistol grip?
    d. ability to accept bayonet?
    e. flash suppressor?
    f. bipod?
    g. grenade launcher?
    h. night sights?

    2. Is the weapon a semiautomatic version of a machinegun?

    3. Is the rifle chambered to accept a cartridge case having
    a length of 2.25 inches or less?

    4. How has the rifle been advertised/marketed?


    5. Technical Writers Descriptions:

    The ATF feels that the VALMET Hunter is a sporting rifle,
    but the M76 Counter Sniper is not. I would say that a PSL
    lacking provisions for a flash suppressor,night sights,grenade launcher,
    bi-pod,bayonet,folding stock,or magazines greater than 10 rounds
    and a thumbhole stock meets the definition of a sporting rifle.

    You would have to write the ATF for a firm decision, as it seems
    that anything with a pistol grip is somehow non-sporting.


    Mark

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    Gunco Veteran White Devil's Avatar
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    Great info Mark I was wondering the same thing about my PSL I just bought.
    Officer...The devil made me do it.....thats my story and I'm sticking to it.

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    Gunco Maniac sjohnson's Avatar
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    Going by the original AWB definition,

    Semi-automatic rifles able to accept detachable magazines and two or more of the following:

    * Folding or telescoping stock
    * Pistol grip
    * Bayonet mount
    * Flash suppressor, or threaded barrel designed to accommodate one
    * Grenade launcher (more precisely, a muzzle device which enables the launching or firing of rifle grenades)

    You could have any ONE of a the "evil" features and it'd still be a sporting rifle. I've seen no ATF ruling on what exactly constitutes a "sporting" rifle, so it's conjecture just what may or may not be present on a PSL before it loses it's importable "sporting" status.

    And what about PSL rifles built in the U.S.? They're not imported rifles, but built with imported parts. 922r states:

    "(a) No person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph (c) of this section if the assembled firearm is prohibited from importation under section 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes."

    The PSL isn't prohibited from importation, yet those that are imported often (though not always) have the bayo lug ground off. The muzzle device is, AFAIK, considered a muzzle brake and not a flash suppressor.

    FWIW

    YMMV, hair may fall out, you might find you're gay, women may find you repulsive, little children may scorn you.
    I have a daughter. I tell her, "911 is what you dial after you're raped. 1911 is what you should have before they try."

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    Gunco Veteran Markp's Avatar
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    Quote Originally Posted by sjohnson View Post
    You could have any ONE of a the "evil" features and it'd still be a sporting rifle. I've seen no ATF ruling on what exactly constitutes a "sporting" rifle, so it's conjecture just what may or may not be present on a PSL before it loses it's importable "sporting" status.
    Which is why we have to go back to the 1989 ATF report on "Report and Recommendation on the Importability of Certain Semiautomatic Rifles."

    "On March 14, 1989, ATF announced that it was suspending, effective
    immediately, the importation of several makes of assault-type
    rifles, pending a decision as to whether these weapons meet the
    statutory test that they are of a type generally recognized as
    particularly suitable for or readily adaptable to sporting
    purposes. The announcement stated that ATF would not approve,
    until further notice, the importation of AKS-type weapons, Uzi
    carbines, FM/FAL-type weapons, FN/FNC-type weapons and Steyr Aug
    semiautomatic weapons. On April 5, 1989, the suspension was
    expanded to include all similar assault-type rifles.

    For purposes of this suspension, assault-type rifles were rifles
    which generally met the following criteria:

    a. military appearance

    b. large magazine capacity

    c. semiautomatic version of a machinegun"


    http://www.cs.cmu.edu/afs/cs/user/wb...989_report.txt

    This gives examples of allowed and prohibited weapons. Unfortunately it shows that they were not consistent in the application of the criteria all the time. Since the PSL does not have a large magazine capacity, is not a semi-auto version of a machine gun, and generally does not have a military "appearance", "appearance" being equated to military features and not sinister looks... Military appearance is pistol grips, night sights, bayonet lug, grenade launcher, etc. Then the PSL is unlikely to meet the criteria to ban it from import.

    Enjoy

    Mark

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    Gunco Veteran AKarl_12's Avatar
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    Quote Originally Posted by Markp View Post
    Which is why we have to go back to the 1989 ATF report on "Report and Recommendation on the Importability of Certain Semiautomatic Rifles."

    "On March 14, 1989, ATF announced that it was suspending, effective
    immediately, the importation of several makes of assault-type
    rifles, pending a decision as to whether these weapons meet the
    statutory test that they are of a type generally recognized as
    particularly suitable for or readily adaptable to sporting
    purposes. The announcement stated that ATF would not approve,
    until further notice, the importation of AKS-type weapons, Uzi
    carbines, FM/FAL-type weapons, FN/FNC-type weapons and Steyr Aug
    semiautomatic weapons. On April 5, 1989, the suspension was
    expanded to include all similar assault-type rifles.

    For purposes of this suspension, assault-type rifles were rifles
    which generally met the following criteria:

    a. military appearance

    b. large magazine capacity

    c. semiautomatic version of a machinegun"


    http://www.cs.cmu.edu/afs/cs/user/wb...989_report.txt

    This gives examples of allowed and prohibited weapons. Unfortunately it shows that they were not consistent in the application of the criteria all the time. Since the PSL does not have a large magazine capacity, is not a semi-auto version of a machine gun, and generally does not have a military "appearance", "appearance" being equated to military features and not sinister looks... Military appearance is pistol grips, night sights, bayonet lug, grenade launcher, etc. Then the PSL is unlikely to meet the criteria to ban it from import.

    Enjoy

    Mark
    I was just looking to get a PSL kit and was wondering the same thing.
    So what you are saying is that the PSL does not fall under the 922r compliant laws, that is why I have not seen any compliant parts list.

  8. #7
    Gunco Veteran Markp's Avatar
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    Quote Originally Posted by AKarl_12 View Post
    I was just looking to get a PSL kit and was wondering the same thing.
    So what you are saying is that the PSL does not fall under the 922r compliant laws, that is why I have not seen any compliant parts list.
    What I am saying is: My personal interpretation is that the PSL is NOT a rifle that would be prohibited under 925(d)(3) as not being suitable for sporting use as evidenced by the fact that the PSL is currently being imported by several companies as manufactured in Romania and in absence of any guidance from the ATF. To me this is sufficient evidence that this rifle is not subject to 922(r)

    YMMV, I am not a lawyer, please consult one should you have any concerns.


    Mark

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    Gunco Maniac sjohnson's Avatar
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    What's the purpose in citing a 1989 ruling?

    With AK-type weapons importable today, how does a ruling that doesn't apply to AK weapons any more suddenly bear weight on the PSL?

    Also, using "the receiver is the firearm" approach used to determine NFA status, since the actual PSL is built with the safety sear and third receiver hole, how can it be explained that a semi-only receiver build of a PSL clone not be a "c. semiautomatic version of a machinegun"?

    Note, I'm not arguing for or against 922r status of the PSL. Just throwing out thoughts.
    I have a daughter. I tell her, "911 is what you dial after you're raped. 1911 is what you should have before they try."

  10. #9
    Gunco Veteran Markp's Avatar
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    Quote Originally Posted by sjohnson View Post
    What's the purpose in citing a 1989 ruling?

    With AK-type weapons importable today, how does a ruling that doesn't apply to AK weapons any more suddenly bear weight on the PSL?

    Also, using "the receiver is the firearm" approach used to determine NFA status, since the actual PSL is built with the safety sear and third receiver hole, how can it be explained that a semi-only receiver build of a PSL clone not be a "c. semiautomatic version of a machinegun"?
    Because the PSL (as far as I know) despite having the third pin was never select fire (It was used for a safety sear.) Correct me if I am wrong.

    Additionally the WASR's and other AK style rifles cannot be sold unless they have their muzzle brakes welded, bayonet lugs ground off, single stack mags, etc. Otherwise they have compliance parts added, as century does with their AK offerings.

    The purpose in citing the 1989 policy is because that is the logic and criteria that is still used today in determining which rifles are legal for import and which are not (AFAIK.) If you have a more recent policy letter or report, feel free to correct me, this is the latest one I am aware of. So the report still applies and those weapons listed in the report are still prohibited in their original configuration from importation.

    I am not an expert in this area, nor am I pretending to be, I am just presenting the best information I have. I really encourage everyone to correct me if I am wrong and provide more up to date information should it exist.

    Mark

  11. #10
    Gunco Maniac sjohnson's Avatar
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    I think we're basically in agreement. Like the WASR, the PSL has a fixed muzzle device, bayonet lugs ground off and low-cap mags (original 10 round mags, with no mass-produced higher capacity mags).

    If you start changing the as-imported configuration of the PSL, I wonder how the ATF would view it? Certainly they place modified WASR rifles under the 922r umbrella.
    I have a daughter. I tell her, "911 is what you dial after you're raped. 1911 is what you should have before they try."

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