DEPARTMENT OF THE TREASURY
             BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
                      WASHINGTON, DC 20226

                                             F:SD:FTB:MJC
                                             3311
                         OCT 24 1997


Dear Mr. ;

This refers to your FAX of September 30, 1997, in which you request
information on a certain part in the description of imported parts
listed in 27 CFR, Part 178.39(c). The part in the list to which you
refer is Forearms, handguards, You ask if the forearm, handguard
parts for the MAK-90 type rifles were made in the United States
would this reduce the number of imported parts on this rifle.

Section 922(r) of the Gun Control Act (GCA) prohibits assembly of
certain semiautomatic rifles and shotguns from imported parts. The
implementing regulations in section 178.39 of Title 27, Code of
Federal Regulations provide that no person shall assemble a
semiautomatic rifle or any shotgun using more than 10 of the
following imported parts if the assembled firearm is prohibited
from importation under section 925(d)(3) of the GCA as not being
particularly suitable for or readily adaptable to sporting
purposes:

(1)   Frames, receivers, receiver castings, forgings
      or stampings
(2)   Barrels
(3)   Barrel extensions
(4)   Mounting blocks (trunnions)
(5)   Muzzle attachments
(6)   Bolts
(7)   Bolt carriers
(8)   Operating rods
(9)   Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors

                              - 2 -

(15) Buttstocks
(16) Pistol grips
(17) Forearms, handguards 
(18) Magazine bodies 
(19) Followers
(20) Floorplates

The forearm on an AK type rifle is the portion, usually made of
wood or plastic, in front of the receiver which covers the bottom
of the barrel. The handguard is the portion, usually made of wood
or plastic, in front of the receiver which covers the gas tube
located above the barrel.

For the purposes of the above list of parts, Forearms, handguards,
means with respect to AK type weapons the handguard and the
forearm. Therefore, if both these components were manufactured in
the United States they would not be considered an imported part.

AK style rifles having threaded muzzles, flash hiders, bayonet
lugs, military style buttstocks with a separate pistol grip, or
folding or telescoping buttstocks are prohibited from importation;
therefore, such rifles cannot be assembled if the rifle uses more
than to of the imported parts in section 178.39. MAK-90 style
rifles having one-piece thumbhole sporter buttstocks, without
threaded muzzles, flash hiders, or bayonet lugs are approved for
importation and may be lawfully assembled using more than 10 of the
imported parts.

A semiautomatic rifle having only 10 or less of the imported parts
is not required to qualify for importation, However, a
semiautomatic rifle having an ability to accept a detachable
magazine and two or more of the following features would be a
semiautomatic assault weapon as that term is defined in section
921(a)(30)(B) of the GCA:

(i) a folding or telescoping stock;

(ii) a pistol grip that protrudes conspicuously beneath the action
     of the weapon;

(iii) a bayonet mount;

                              - 3 -

(iv) a flash suppressor or threaded barrel designed to accommodate
     a flash suppressor; and

(v) a grenade launcher;

It is unlawful for anyone to manufacture, possess, or transfer a
semiautomatic assault weapon except as provided in section 922(v)
of the GCA. A semiautomatic assault weapon which was lawfully
possessed on September 13, 1994, may still be lawfully possessed
and transferred. A firearm which did not meet the definition of a
semiautomatic assault weapon on September 13, 1994, does not
qualify for this exemption.

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


                        Sincerely yours,

                            [signed]

                      Edward M. Owen, Jr. 
                Chief, Firearms Technology Branch