DEPARTMENT OF THE TREASURY
             Bureau of Alcohol, Tobacco and Firearms
                     Washington, D.C. 20226

                           AUG 13 1997            E:CE:FT:EMO
                                                  3311

Dear Mr. :

This refers to your letter of July 30, 1997, in which you ask
additional questions about the number of imported parts contained
in rifles based on the AK 47 that are imported into the United
States.

Title 27 CFR, Section 178.39(a) states that 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 (emphasis added) is prohibited from importation
under section 925(d)(3) as not being particularly suitable for or
readily adaptable to sporting purposes.  Firearms based on the AK
47 design are not approved for importation with separate pistol
grips, folding stocks, bayonet mounts, threaded muzzles, flash
suppressors, grenade launchers, night sights or bipod mounts.

Therefore, if you assemble an AK type firearm using more than 10
imported parts listed in paragraph (c), the assembled rifle must
have a one piece thumb hole style stock and may not have a separate
pistol grip, folding stock, bayonet mount, threaded muzzle, flash
suppressor, grenade launcher, night sight or bipod mount.

If you plan to assemble an AK type weapon using 10 or less of the
imported parts listed in paragraph (c), the rifle is not required
to have a one-piece thumbhole style stock.  However such rifle many
not be in a configuration that meets the definition of
semiautomatic assault weapon as that term is defined in 18 U.S.C.,
Chapter 44, Section 921(a)(30).

                              - 2 -

You also asked about marketing a parts kit containing a combination
of domestic and imported parts.  In order to respond to your
inquiry concerning the legality of using these parts on an imported
AK type rifle, it is requested that a sample of the parts kit be
submitted.

We trust that the foregoing has been responsive to your inquiry. 
If we can be of any further assistance, please contact us.


                        Sincerely yours,
                            [signed]
                       Edward M. Owen, Jr.
                Chief, Firearms Technology Branch