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Akdal MKA 1919 Shotgun Review
Part 7 - Flash Suppressor & High Capacity Magazine Legal
June 19, 2012
The MKA 1919 Shotgun clearly has some great features in it's "as is" configuration right out of the box. A couple of these features being it's operational similarity to AR style rifles and it's ability to be a magazine fed 12 gauge shotgun. Although, I believe it greatest potential as a weapons platform is achieved by turning this imported "sporting purpose" shotgun into a true tactical platform shotgun. Some may argue on what the features are that would define a true tactical shotgun, but most will agree that having a magazine capacity of greater than 5 rounds is a must. Another feature would be the addition of a tactical choke for breeching and striking purposes and some could consider it a flash suppressor. Since the MKA 1919 is imported from Turkey, there are some legal issues associated with making the conversion to a tactical shotgun other than just sticking in a high capacity magazine and screwing in a tactical choke. In this part of the review, I'm going to go over some laws and regulations with regard to the MKA 1919 Shotgun and show you how I converted my MKA 1919 Shotgun to be legal for using high capacity magazines and a tactical choke.
Before I get into the details of the shotgun conversion, lets first get a basic understanding of these laws and regulations. I also want to say that you should not consider this review to be legal advice. This review represents my interpretation of these laws and regulations and you should take the time to do your own research and hopefully you will come to the same conclusion. If not, feel free to send me an email at editor@gunsumerreports.com and I will try to look into any differences in what you may find and update this review if needed.
Laws & Regulations
The basic laws and regulations stem from Title 18 United States Code (USC) Chapter 44 Section 922 (r), Section 925 (d)(3) and Section 5845 (a), along with Title 27 Code of Federal Regulations (CFR) Section 448.39.
The Federal Firearms Regulation Reference Guide 2005 states the information for Title 18 USC Chapter 44 Sections 922 (r) and 925 (d)(3) as follows. Keep in mind that the text in colored italics was taken directly from the referenced documents and the white text is my interpretation and comments.
Section 922 (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 ...
My words: You can not use imported parts to make a rifle or shotgun that is not suitable or ready for "sporting purposes".
Section 925 (d)(3)
(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—
(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 1954 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;
Internal Revenue Code Section 5845 (a)
(a) Firearm. The term 'firearm' means
- (1) a shotgun having a barrel or barrels of less than 18 inches in length;
- (2) a weapon made from a shotgun if such weapon as modified has an overall length of less than 26 inches or a barrel or barrels of less than 18 inches in length;
- (3) a rifle having a barrel or barrels of less than 16 inches in length;
- (4) a weapon made from a rifle if such weapon as modified has an overall length of less than 26 inches or a barrel or barrels of less than 16 inches in length;
- (5) any other weapon, as defined in subsection (e);
- (6) a machinegun;
- (7) any silencer (as defined in section 921 of title 18, United States Code); and
- (8) a destructive device.
The term 'firearm' shall not include an antique firearm or any device (other than a machinegun or destructive device) which, although designed as a weapon, the Secretary finds by reason of the date of its manufacture, value, design, and other characteristics is primarily a collector's item and is not likely to be used as a weapon.
My words: You can import a firearm as long as it is not a Class III weapon and is suitable for "sporting purposes".
The best source I have found so far for helping to understand "sporting purposes" is the ATF Study on the Importability of Certain Shotguns. In the study the ATF was able to define that certain shotgun features are not particularly suitable or readily adaptable for sporting purposes. These features include:
- (1) Folding, telescoping, or collapsible stocks;
- (2) bayonet lugs;
- (3) flash suppressors;
- (4) magazines over 5 rounds, or a drum magazine;
- (5) grenade-launcher mounts;
- (6) integrated rail systems (other than on top of the receiver or barrel);
- (7) light enhancing devices;
- (8) excessive weight (greater than 10 pounds for 12 gauge or smaller);
- (9) excessive bulk (greater than 3 inches in width and/or greater than 4 inches in depth);
- (10) forward pistol grips or other protruding parts designed or used for gripping the shotgun with the shooter’s extended hand.
This above helps you to understand why the MKA comes without some of the features you would want on a tactical shotgun such as adjustable stock, magazines over 5 rounds, handguard rails and flash suppressors. So what can we do to convert this shotgun to make it legal for non-sporting purposes? The short answer is to reduce the number of imported parts so it complies with this next regulation.
Title 27 C.F.R. 478.39 identifies 20 significant parts of which you must have no more than 10 on your shotgun if you plan to convert it to one that is not "particularly suitable for sporting purposes" (i.e. to use a high capacity magazine). This section of the code is shown below.
(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.
(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 (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
Looking at this list leads you to think it is easy to make a determination when counting imported parts, but questions come in like:
- Is an internal choke really a muzzle attachment?
- Does an integrated buttstock, pistol grip and lower receiver count as one part or three parts?
- Are the upper and lower receivers considered one part or two?
To keep yourself on the right side of the law, I recommend exercising conservatism where possible or getting your hands on an official letter from the BATFE stating the imported parts count for your imported firearm.
MKA 1919 Shotgun Parts
Now that you understand a little about the laws, next you need to understand the parts in the MKA 1919 Shotgun. This figure below was the level that I disassembled the MKA 1919 Shotgun during my review.
Figure 1
This next figure below comes directly from the Owner's Manual for the MKA 1919 Shotgun and the numbered items in the figure are listed below.
Figure 2
The diagram provided with the owner's manual doesn't breakdown the parts in the magazine or lower receiver so I have added another list of parts in the right column to identify potential imported parts.
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While doing my research on the internet, I found that there were different interpretations on the imported parts count for the MKA 1919. My initial most conservative estimate was as high as 17 parts and as low as 13 parts. Because this difference was so great and the cost of potentially replacing 7 parts was more than I thought practical, on May 9, 2012, I sent a letter to the BATFE asking them for clarification. In the letter, I sent the above two photos and the list of parts to the BATFE and asked them to provide me a list of parts that would be considered imported parts on the MKA 1919 Shotgun. On June 16, 2012, I received the BATFE's reply and these next two photos show the letter I received in response to my questions.
Figure 3 - BATFE Letter Page 1
Figure 4 - BATFE Letter Page 2
In summary, the BATFE found there to be 14 imported parts on the MKA 1919 shotgun. The only thing that struck me as odd in their response was their identification of a "Mounting Bocks (Trunnions)" as an imported part. I interpreted this to mean that they are saying the lower receiver is considered to be a mounting block. They also made the clarification that "any firearm component that combines in its design, multiple "parts"... would only count as a single "part" for the purposes of § 478.39". This statement completely cleared up the question of how to count the buttstock, pistol grip and lower receiver since it only counts as one part. The table below lists the imported parts and the parts I intend to swap on my shotgun so that it is capable of having a tactical choke (flash suppressor) and using high capacity magazines. I also added another column to show the parts count when using a Firebird Precision magazine extender and another column to show this list with a 100% American made high capacity magazine. Warning, if you decide that you want to install an AR style adapter for a different pistol grip or a telescoping buttstock, since you will be cutting off the original parts which were considered part of the single part (lower receiver / mounting block), you will need to make sure the new parts are either 100% American made or you will need to reevaluate your imported parts count.
| Configuration (see comments below) |
A | B | C | D |
| Part | Imported Part Per BATFE Letter | With
USA Made Parts |
With Firebird Precision Magazine Extension | With 100% USA Made Magazine |
| Choke | - | Trulock | Trulock | Trulock |
| Receiver (upper) | 1 | 1 | 1 | 1 |
| Barrel | 1 | 1 | 1 | 1 |
| Mounting Block (lower receiver) | 1 | 1 | 1 | 1 |
| Bolt | 1 | 1 | 1 | 1 |
| Bolt Carrier | 1 | 1 | 1 | 1 |
| Operating Rod | 1 | 1 | 1 | 1 |
| Gas Piston | 1 | Tromix | Tromix | Tromix |
| Trigger | 1 | Tromix | Tromix | Tromix |
| Hammer | 1 | 1 | 1 | 1 |
| Disconnector | 1 | Tromix | Tromix | Tromix |
| Handguards | 1 | 1 | 1 | 1 |
| Magazine Body | 1 | 1 | 1 | TBD |
| Magazine Follower | 1 | 1 | 1 | TBD |
| Magazine Floorplate | 1 | Tromix | Firebird | TBD |
| Total Imported Parts | 14 | 10 | 10 | 8 |
| Flash Suppressor Legal? | Maybe | Yes | Yes | Yes |
| High Capacity Magazine Legal? | No | Yes | Yes | Yes |
| Magazine Capacity | 5 | 5 | 10 | TBD |
Configuration Comments:
- This represents the "as received" shotgun with a total of 14 imported parts.
- This configuration represents a "flash suppressor" legal configuration. Adding the four Tromix parts brings the total imported parts count down to 10, but you still only have a 5-round magazine. Honestly, I'm not 100% sure if the BATFE would consider adding a tactical choke as making the shotgun "non sporting purpose" because I see shotguns imported into the USA that clearly have a tactical style choke (ex. TriStar Cobra Force Pump, see Figure 3). Since a flash suppressor was identified as being a feature that makes a shotgun non sporting, I think it is better to be on the safe side and make sure your parts count is down to 10 imported parts before installing the Trulock Tactical Choke.
- At the time of this review, the only high capacity magazines available are actually a blend of the original magazine parts and an American made magazine extension which becomes the new floorplate. These magazine extensions are made by Firebird Precision and give you a 10 round magazine capacity.
- Fortunately, replacing the magazine can work in your favor when replacing imported parts. At the moment, I have not found a source for 100% American made high capacity magazines, but I'm sure it will not be long before someone steps to the table to capitalize on this money making opportunity. Once we finally have an American manufacturer produce a 100% high capacity magazine, the imported parts count drops down to 8 parts which would allow you to add some imported parts back like pistol grip and collapsing buttstock. Now for a quick word of warning, if you increase your parts count by adding imported parts back to your shotgun and then use the original imported magazines, you just crossed the line to the wrong side of the law by adding back 3 imported parts. The key point it to always replace/add American made parts. You should also consider that when 100% American made magazines are available, you only need to replace a single additional part at minimum since the magazine will replace the other three parts.
Tromix Gas Piston, Trigger & Disconnector and Floorplate Replacement Parts
The MKA 1919 Shotgun starts out with 14 imported parts and I needed to reduce the parts count by another 4 parts. By doing a search on the internet for "MKA Parts", I found that two companies are already making aftermarket parts for the MKA 1919 Shotgun. These two companies are Firebird Precision and Tromix. After looking at the replacement parts provided by both of these companies, I decided to go with the Tromix parts because they seemed to provide the lowest cost and easiest to swap options for making this shotgun high capacity magazine and flash suppressor legal.
While studying the parts Tromix offered, and knowing I needed to get my total imported parts count done by at least four, I selected the Tromix Gas Piston (T19-03, $35), the Tromix Trigger & Disconnector (TR19-06, $25), and the Tromix Magazine Base Plate (TR19-02, $25). TROMIX states that the Trigger & Disconnector counts as two imported parts, so replacing these items will bring my parts count down to 10 imported parts.
The Tromix Gas Piston is machined from 17-4 stainless steel and is shown below. I like the fact that Tromix machines a "T" into the end of the part to help identify this part from the original.
Figure 3
Figure 4
Figure 5
Figure 6
There are some other slight differences between the two parts like the chamfer on the end of the original gas piston and slight profile differences as shown below. The hardest part for replacing this part is removing the metal ring seal and transferring it to the Tromix gas piston. Not having the correct pliers, it took me three hands to hold the gas piston, expand the ring and then slide a small screwdriver under the ring to work the ring off the piston.
Figure 7
Original
Tromix
To install the gas piston you will need to remove the barrel. You can see details on how to remove the barrel at my MKA 1919 Disassembly page. With the barrel removed, just swap out the two pistons after moving the metal ring seal. Also notice in the photo below that there is another part between the gas regulator spring and nut. This new part is a Tromix Bas Booster Bushing (T19-01, $9). According to Tromix, the bushing is: "CNC machined from 17-4 stainless. These bushings are installed on the top of the gas bypass spring which increases preload and decreases total bypass piston travel, thus allowing your gun to cycle lighter ammunition. Bushing should be removed when firing heavy loads." So far I haven't had any issue cycling lighter loads, but I still have not shot the lightest or reduced recoil shells. If you are ordering the other Tromix parts, I would recommend adding this one to your order to have if ever needed since it is only $9.
Figure 8
The Tromix Trigger & Disconnector is actually sold as a three piece set (trigger, disconnector and disconnector spring). These parts are not interchangeable with, nor will they work with the original trigger, disconnector, or spring. The Tromix parts are shown below.
Figure 9
Figure 10
Figure 11
To replace the trigger and disconnector, you will need to remove the upper receiver. Again, you can see details on how to do this at my MKA 1919 Disassembly page. With the upper receiver removed, you will first need to remove the manual safety. To do this, remove the plug shown below. Under the plug is a spring and plunger. Once the plunger is removed, you can slide the safety out of the lower receiver.
Figure 12
Next you will need to push the hammer pin out of the lower receiver. Before you do this, make sure you study the placement of the spring legs inside the receiver so you can reassemble the components properly. Also, decock the hammer to reduce the spring force. Using a punch and the back of a screwdriver as a hammer, I was able to tap the hammer pin out of the receiver. Since the pins have a knurling on one end, pushing them from left to right seemed to be the correct direction to keep from passing the knurled end through the receiver. Start by pressing the pin out slightly and making sure your pushing the pin in the right direction based on which side has the knurling. As you are pressing the pin out, you will need to hold down on the hammer and spring so they don't fly across the room.
Figure 13
Next you will use a similar technique as above to remove the trigger/disconnector pin.
Figure 14
When all the components are removed, they should look something like the photo below.
Figure 15
These next two photos compare the original trigger and disconnector against the Tromix parts and you can see that there are some real differences. Immediately you will notice that the Tromix trigger is a complete metallic part compared to the polymer original trigger.
Figure 16
Original
Tromix
There are also some clear profile difference between the two disconnectors.
Figure 17
Original
Tromix
The photo below shows the parts installed and the steps for assembly are basically the reverse of the disassembly process. Once installed, the parts all seemed to function properly and I believe the trigger pull got a little smoother.
Figure 18
The Tromix magazine base plate (floorplate) is machined from aluminum as shown below and comes in a bare (uncoated) finish. This makes it really stand out so you will know which magazine has the American made part. My preference would be some type of black anodizing and this one may end up with a coat of paint on the exterior surfaces at some point.
Figure 19
Figure 20
Figure 21
Installing the base plate is done by pushing down on the magazine spring seat and sliding the original base plate off and the new Tromix base plate back on.
Figure 22
Figure 23
Trulock Tactical Choke
I decided to go with a Trulock Tactical Choke for several reasons. The first was that the Trulock chokes are 100% American made which for me is the number one requirement to keep it from ever being considered as an imported part. Next, Trulock makes a quality choke which should be able to withstand some real punishment if needed. Trulock states: "The Trulock Tactical Choke was designed to produce optimum performance with breaching rounds, buckshot and rifled slugs. This eliminates the need to change muzzle devices when alternating ammunition from breaching rounds to buckshot or rifled slugs. The crenulated muzzle ensures positive grip when used as a standoff tool. More than just a breaching tool, this new design goes beyond a single purpose. The Trulock Tactical Choke produces improved downrange accuracy and performance for buckshot or rifled slug applications."
The next several photos give you a good look at the Trulock Tactical Choke. You can purchase this tactical choke at the Trulock website for $58.99 plus S&H.
Figure 24
Figure 25
Figure 26
Figure 27
The threads seemed to be a perfect match and installation was just a matter of unscrewing the old choke and screwing in the new Trulock Tactical Choke. Since I don't have long throat calipers or a barrel gauge, I was not able to measure the constriction of the choke. Trulock states a 0.000" constriction which would match the use with buckshot or rifled slugs.
Figure 28
Figure 29
Thoughts
The photo below shows what I defined as Configuration B in the table above. The MKA 1919 shotgun is now down to only 10 imported parts and can legally have a flash suppressor. In this configuration the shotgun is still limited to a 5 round capacity since I did not increase the capacity of the original magazine. To this point, the components cost $144 plus S&H (not including the gas booster bushing). If you are not interested in a tactical choke configuration, then I recommend foregoing the cost of the tactical choke and new base plate. Doing so brings your conversion parts cost down to $60 plus S&H to setup your shotgun to be ready for high capacity magazines extensions (available at Firebird Precision) or 100% American made magazines (which are not available yet). Maybe it's just the "tacti-cool" in me, but honestly, I can't imagine someone not wanting to add a tactical choke.
Figure 30
Once I do some range testing with this new configuration, I will confirm that the MKA 1919 shotgun functions properly with the new Tromix gas piston, trigger and disconnector and update this part of the review with comments. In the next part of this review, I'm hoping to cover the Firebird Precision High Capacity Magazine Extensions (once I can get my hands on some), so check back in the near future for Part 8 of my MKA 1919 review.
For more detailed photos and commentary, make sure you check out the other parts of this review and feel free to leave comments on my Reader's Comments page or below. The following links are provided to help you see other parts of this review.
- MKA 1919 Shotgun Review: Part 1 - Introduction, Specifications and Summary
- MKA 1919 Shotgun Review: Part 2 - What's in the Box
- MKA 1919 Shotgun Review: Part 3 - External and Operational Features
- MKA 1919 Shotgun Review: Part 4 - Disassembly
- MKA 1919 Shotgun Review: Part 5 - Internal Features
- MKA 1919 Shotgun Review: Part 6 - Range Test
- MKA 1919 Shotgun Review: Part 7 - Flash Suppressor & High Capacity Magazine Legal (this page)
- MKA 1919 Shotgun Review: Reader's Comments
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