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

                           APR 2 1999
                                             903050:GKD
                                             3311


Dear Mr. :

This refers to your letter of November 2, 1998, requesting
information on the legality of installing a contoured handgrip and
an adjustable buttstock, both as found on a Heckler and Koch PSG-1
semiautomatic rifle on to a Springfield Armory SAR8 semiautomatic
rifle.

Title 18 United States Code (U.S.C.), Chapter 44, section 922(r)
provides that:

It shall be unlawful for any person to assemble from imported parts
any semiautomatic rifle or any shotgun, which is identical to any
rifle or shotgun prohibited from importation under section
925(d)(3) of this chapter as not being particularly suitable for or
readily adaptable to sporting purposes.

Title 27 Code of Federal Regulations (CFR), Part 178, section
178.11, in part, provides:

(a) No person shall assemble a semiautomatic rifle or any shotgun
using more than ten 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.

(c) For purposes of this section, the term "imported parts" are:

                              - 2 -

Mr.

     (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.

     (15) Buttstocks.

     (16) Pistol grips.

     (17) Forearms, handguards.

     (18) Magazine bodies.

     (19) Followers.

     (20) Floorplates.

                              - 3 -

Mr.

In April, 1998, importation of 58 semiautomatic rifles was banned
due to their ability to accept large capacity military magazines. 
The SAR8 rifle was one of the firearms included in this ban.

Installation of a contoured handgrip and/or an adjustable buttstock
such as those found on the PSG-1 rifles on to a Springfield Armory
SAR8 semiautomatic rifle would constitute assembly of a non-
importable semiautomatic rifle, hence that assembly would be a
violation of section 922(r) cited above.

We regret that our response could not be more favorable.  If we can
be of any further assistance, please contact us.


                       Sincerely yours,


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