Making the Benelli M4 922r Compliant

This article and the information contained in this website is not intended to provide legal advice in any way. The laws change, enforcement policies change without notice. Contact the BATF directly to get current and up to date information.

Benelli M4 922r Compliance. Section 922R makes no sense. As an example, I purchased a Benelli M4 which is made in Italy and imported as a sporting shotgun which can have no more than a 5 round magazine capacity. To increase capacity to 7 rounds by adding a magazine extension the shotgun becomes illegal. But it is easy to make the Benelli M4 922R compliant. Simply replace the complete original Benelli magazine tube, the original Benelli magazine follower, and the original Benelli fore end with US made 922R compliance parts. The installation of the 3 US made parts makes the Benelli M4 922R compliant and legal. It is interesting to note that the US made fore end is a copy of the original imported Benelli part but all the same makes the M4 922R Compliant and legal.

Benelli M4 Super 90

Benelli M4 Super 90


The Benelli M4 shotgun with original pistol grip stock has 13 designated imported parts on the 922R compliance parts list. This means I have to replace 3 imported parts with US made parts to reduce the imported parts count to 10 or less. If the M4 has an original collapsible stock then it has 14 imported parts and 4 imported parts must be replaced with US made parts to achieve the imported parts count to 10 or less. The collapsible stock is counted as two items, the stock, and the pistol grip.

In short, federal law prohibits us from increasing the magazine capacity on our Benelli M4 shotguns to more than 5 rounds. However, there is a way around this by keeping the shotgun in compliance with 922R. We can achieve this by keeping the imported parts count to 10 or less.

Here are the imported parts in the Benelli M4 shotgun. Listed are 13 items. Changing the magazine to increase capacity requires that the shotgun meet the 922R regulation which requires that it can have no more than 10 of the imported parts listed.

Your M4 can’t have more than 10 imported parts from the list – which is how we arrive at the number of 3 parts that must be completely removed and replaced with American made parts.

  1. Receiver
  2. Barrel
  3. Bolt
  4. Bolt carrier
  5. Gas piston
  6. Trigger housing
  7. Trigger
  8. Hammer
  9. Disconnector
  10. Butt stock (with integral pistol grip)
  11. Fore end/hand guard
  12. Magazine body – magazine tube
  13. Follower – magazine follower

You can decide to replace any of the items on the list, but the M4 easily meets the regulation by installing a full length magazine tube, a US made magazine follower, and a US made fore end. Adding the magazine extension won’t count because the original tube is still on the gun. Other US made parts are available such as:

  • Pistol Grip Stock with 12 1/2 inch LOP – Available from TAPCO
  • Trigger group – Available soon from Carrier Comp
  • Trigger – Available soon from Carrier Comp
  • Hammer – Available soon from Carrier Comp

BATF will answer your request for a parts count clarification on your particular imported weapon. To send you own letter to BATF use the following address:

Chief, Firearms Technology Branch
Bureau of Alcohol, Tobacco, and Firearms
Firearms Technology Branch
244 Needy Road
Martinsburg, WV 25401

Here is a link to my original article install Benelli M4 magazine extension.

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