Benelli M4 922r
Benelli M4 922(r) Summary:
To increase magazine capacity to over five rounds or add a collapsible stock (or a recoil tube that makes your “collapsible stock” collapse), swap either three or four parts with American-made parts (four if you have a collapsible stock since it is two separate parts) from the list of 20 below.
922(r) Explanation for the Benelli M4/M1014
922(r) is a federal law that involves foreign-made rifles and shotguns. It only applies when you're increasing magazine capacity to over 5 rounds and/or adding a stock that collapses (or if you have a "fixed collapsible stock", installing a recoil tube that has multiple positions).
Since Benelli makes their shotguns in Italy, they are required to follow 922r compliance if they want to sell their shotguns to American civilians lawfully. To stay compliant, they import their Benelli M4s with magazine capacities of 5 rounds and come with either a fixed-length stock or a collapsible stock with a non-collapsible recoil tube.
922(r) laws are the reason why Benelli imports their civilian model Benelli M4s in the "neutered" configuration (fixed stock, and low capacity).
If you want to increase magazine capacity to over 5 rounds, and/or have a stock that collapses down to shorter lengths of pull, we recommend you consider following 922(r) rules to keep your shotgun compliant and legal.
How to make your Benelli M4 922(r) compliant:
You will want to swap out Italian-made parts for American-made parts, but not just any random parts. The ATF has a list of 20 specific parts to swap from Italian to American-made parts.
To make your Benelli M4 922(r) compliant, you can have no more than 10 of the ATF's 20 specific parts (list below) installed if you want a magazine capacity larger than 5 rounds, and/or a stock that collapses.
When you buy a Benelli M4 in factory configuration (non-law enforcement or military models), it comes installed with 13 of the 20 specific parts if you purchased a one-piece, fixed-length stock (polymer pistol grip or polymer field versions). If you bought a model with a collapsible stock, it comes installed with 14 of the 20 specific parts.
Meaning you only need to swap either 3 or 4 specific parts (depending on your version) with American-made parts. The reason why the collapsible stock requires 4 parts instead of 3 is because the collapsible stock is two pieces (a pistol grip, and a stock), and each piece counts as a specific Italian-made part on the ATF's list.
List of the 20 parts on the ATF list that will count as 922r parts if swapped with American made parts:
- Frames, receivers, receiver castings, forgings, or stampings
- Barrels
- Barrel extensions
- Mounting blocks (trunnions)
- Muzzle attachments
- Bolts
- Bolt carriers
- Operating rods
- Gas pistons
- Trigger housings
- Triggers
- Hammers
- Sears
- Disconnectors
- Buttstocks
- Pistol grips
- Forearms, handguards
- Magazine bodies
- Followers
- Floorplates
As you may have noticed, some of these parts don’t apply to the Benelli M4, such as the:
- Barrel extensions
- Mounting blocks
- Muzzle attachments
- Operating rods
- Sears
- Floorplates
That leaves the list of 13 below to choose from:
List of 13 of the 20 specific parts that the Benelli M4 has from the previous list:
- Receiver
- Barrel
- Bolt
- Bolt carrier
- Gas pistons
- Trigger housing
- Trigger
- Hammer
- Disconnector
- Buttstock
- Forearm or Handguard
- Magazine body (Magazine Tube)
- Follower
- **Pistol Grip - adds and extra part when using the Collapsible Stock (14 instead of 13), because the pistol grip and buttstock are two separate parts.
This is our understanding of 922(r) for the Benelli M4. We are not lawyers, and this is not legal advice. You should do your own due diligence on federal and local laws before altering your shotgun. Contact the ATF for your own specific shotgun build and save their response in case of prosecution. See below for the uninterrupted literature.
If you have any specific questions about 922(r) compliance, please email us at shelltactical@gmail.com, and we will be glad to answer. You can and should directly contact the ATF through their website to get 100% correct and up-to-date information.
922(r) compliance uninterpreted from the literature:
US CODE, TITLE 18, PART 1, CHAPTER 44, SECTION 922, PART (R):
From the US Code: https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title18-section922&num=0&edition=prelim
(r) 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 except that this subsection shall not apply to-
(1) the assembly of any such rifle or shotgun for sale or distribution by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
(2) the assembly of any such rifle or shotgun for the purposes of testing or experimentation authorized by the Attorney General.
US CODE, TITLE 18, PART 1, CHAPTER 44, SECTION 925, PART (d):
From the US Code: https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title18-section925&num=0&edition=prelim
(d) The Attorney General shall authorize a firearm or ammunition to be imported or brought into the United States or any possession thereof if the firearm or ammunition-
(1) is being imported or brought in for scientific or research purposes, or is for use in connection with competition or training pursuant to chapter 751 of title 10;
(2) is an unserviceable firearm, other than a machinegun as defined in section 5845(b) of the Internal Revenue Code of 1986 (not readily restorable to firing condition), imported or brought in as a curio or museum piece;
(3) is of a type that does not fall within the definition of a firearm as defined in section 5845(a) of the Internal Revenue Code of 1986 and is generally recognized as particularly suitable for or readily adaptable to sporting purposes, excluding surplus military firearms, except in any case where the Attorney General has not authorized the importation of the firearm pursuant to this paragraph, it shall be unlawful to import any frame, receiver, or barrel of such firearm which would be prohibited if assembled; or
(4) was previously taken out of the United States or a possession by the person who is bringing in the firearm or ammunition.
From the ATF Website: https://regulations.atf.gov/478-39/2024-13699#478-39
§ 478.39 Assembly of semiautomatic rifles or shotguns.
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.
b. The provisions of this section shall not apply to:
1.The assembly of such rifle or shotgun for sale or distribution by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
2.The assembly of such rifle or shotgun for the purposes of testing or experimentation authorized by the Director under the provisions of § 478.151; or
3.The repair of any rifle or shotgun which had been imported into or assembled in the United States prior to November 30, 1990, or the replacement of any part of such firearm.
c. For purposes of this section, the term imported parts are:
1.Frames, receivers, receiver castings, forgings or stampings
2.Barrels
3.Barrel extensions
4.Mounting blocks (trunions)
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