Where is it made?

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Thread: Where is it made?

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    Where is it made?

    I just purchased a PS90 at a local shop and am filling out a Form 1 to SBR it. I am stuck on 4a Name and address of original manufacturer and or importer of firearm. There are 3 different things on the rifle. In white on the metal part under the rail it says FN Columbia SC. Right below where the magazine rests on the stock it says Fabrique Nationale Herstal Belgium. Below that it says FNH USA Fredericksburg VA. What goes in the box? This is my first ATF form and I don't want any issues. Thanks,


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    Where is it made?


    Belgium

    PS90 SBR Paperwork Step-By-Step

    Last edited by LESTER; 04-23-2017 at 05:30 PM.
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    Thank you, I did see that thread. The original posting was from 2007, and none of the follow ups are since they changed the forms. Most of the information is still relevant, but not all. I didn't know whether FN had started making any PS90 parts in the USA since then. And, of course I am trying to fill out my form on Sunday and they are closed...

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    Sorry if this is posted elsewhere. Looking for the 922R parts list for PS90 - i.e. list of parts on BATFE's 922r compliance list that the BATFE assesses exist on a PS90 so that I can source the right number of US made parts to be 922r compliant. When I SBR'ed my Skorpion I found someone had already contacted the BATFE, gotten a ruling, and that CZ actually published this list. So it was really easy to make sure I could be 922r compliant before I even filed a form 1.

    The PS90 Paperwork Step by Step is really good, but it does not mention this, and unless someone has in writing that 922R does not apply, the safe interpretation of the confusing BATFE rules is that 922(r) does apply when you form 1 SBR a foreign made, imported weapon that meets the 'not particularly suited to sporting purposes guidelines (such as having detachable magazine, flash suppressor, bayonette lug, pistol grip...). I know the PS90 doesn't have all of these features, and it may not have 10 of the 20 BATFE evil parts, but does anyone have this in documentation?

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    Senior Member Merlin's Avatar
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    922r does not apply once you SBR or SBS on a Form 1. Having done a Siaga and a PS90......................
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    "Molon Labe!"

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    NO offense of any kind but I have read that exact thing you stated, and the exact opposite re SBR'ing, both made from folks purporting to be experts. Those arguing take sides re two BATFE memos, the later of which says 922R is required when doing a Form 1 SBR on a foreign made weapon, the former memo is ambiguous, so there seems to be some debate. I've seen this lack of clarity on Beretta forums re the CX4, on Benelli forums re the MP-4, On the High Road, and other forums in general, and on the FiveseveN forum.

    There was zero debate on the CZ forum where you can follow links to CZ's online store, on which CZ actually sells 922R compliance kits explicitly so that when you Form 1 SBR your Skorpion, you will be compliant 922R compliant. Further CZ provided the forum a BATFE approved diagram with the 16 applicable 922R parts denoted precisely in diagram and in a list. And they published a memo from the BATFE stating that SBR'ing a Skorpion does require 922R compliance due to its foreign manufacture, and that the number of the parts therein enumerated was 16. All of which pretty much told me that for that gun, it was applicable

    Nowhere have I seen anyone definitively answer this question for the FN PS90

    It may be that 922R doesn't apply to the PS90 because it lacks a collapsing stock, lacks a bayonette lug, isn't considered to have a pistol grip... but I'd like to find someone who perhaps contacted the BATFE and got a memo back w a ruling.

    So not to doubt you, but in the interest of consensus, does anyone second or dissent from Merlin's input?

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    Senior Member Smurky's Avatar
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    I'm stating an opinion here and it's my feeble understanding of 922r and in no way should be construed as legal advice. The PS90 is already 922r compliant or couldn't be imported and sold in the US as a semi automatic rifle. Additionally it's unlawful to assemble a firearm that would be otherwise banned for sale in the US. The rule applies to semiautomatic rifles and shotguns. Making a CZ Scorpion pistol an SBR requires making it 922r compliant but making a CZ Scorpion carbine an SBR doesn't, it's already 922r compliant or couldn't be sold In the US as a rifle. CZ imported the pistol well before the carbine showed up for sale in the US. The SCARs are similar, they're also 922r compliant.
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    Quote Originally Posted by Smurky View Post
    I'm stating an opinion here and it's my feeble understanding of 922r and in no way should be construed as legal advice. The PS90 is already 922r compliant or couldn't be imported and sold in the US as a semi automatic rifle. Additionally it's unlawful to assemble a firearm that would be otherwise banned for sale in the US. The rule applies to semiautomatic rifles and shotguns. Making a CZ Scorpion pistol an SBR requires making it 922r compliant but making a CZ Scorpion carbine an SBR doesn't, it's already 922r compliant or couldn't be sold In the US as a rifle. CZ imported the pistol well before the carbine showed up for sale in the US. The SCARs are similar, they're also 922r compliant.
    OK that's making sense. Whjere I'm stuck is form 1 is getting a stamp for making a firearm. In this case an SBR, so at that point that you are making a firearm in the uS from parts that are not, doesn't 922 R kick in? 27 C.F.R. 478.39 lists 20 parts. Has someone done a parts count like follows:

    (1) Frames, receivers, receiver castings, forgings or stampings: YES IT HAS 1, So Score = 1
    (2) Barrels, No, assuming you SBR it using a CMMG barrel
    (3) Barrel extensions NO, when SBRed, the barrel (CMMG), adaptors, any thing extension would be US made, so not count
    (4) Mounting blocks (trunions) : NO - i believe a trunion is a mounting block a barrel is pressed into. PS 90 barrel is not press fit into a mounting block, so I'm guessing no trunion
    (5) Muzzle attachments -NO, again if you were to SBR it, yoiu'd put a US made flash hider on it...
    (6) Bolts: YES it has a bolt, count 1, Score = 2
    (7) Bolt carriers: UNKNOWN if the parts would be considered a bolt and a carrier or just a bolt. Lets assume yes, Count = 3
    ( Operating rods: yes - bolt racks with an operating rod, score is 4
    (9) Gas pistons NO
    (10) Trigger housings Yes, Count = 5
    (11) Triggers, let's say you use the replacement trigger, APG?
    (12) Hammers, Yes, Count = 6
    (13) Sears, Yes, Count = 7
    (14) Disconnectors, Let's assume yes, Count = 8
    (15) Butt stocks Yes count = 9
    (16) Pistol grips, No its a thumbhole stock
    (17) Forearms, No, there are no removable forearms or handguards, they are monolithic with the buttstock, not separately added parts
    (1 Magazine bodies Yes, if foreign made, count = 10
    (19) Followers, count = 11
    (20) Floorplates, count =12

    So if you do this kind of analysis, then basically you get the BATFE to rule which parts this gun has. If what I produced above is reasonable, and you can find US made magazine followers and floorpltes, and you use that CMMG barrel, us made thread apadtors/muzzle devices, and the replacement trigger i see a lot of people have, then you'd be 922R compliant. Proper engraving gets you the full Form 1 compliance.

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    I have a memo into the BATFE. I verified by phone myself that the PS90 and all parts are made in Belgium by calling FNH in Virginia.

    I downloaded the P90 armorers manual for scribD and went through all the exploded parts diagrams, below is my plan (to be modified based on BATFE if they reply):

    1. Frames/receiver:... yes, can't change, count = 1
    2. Barrel... change to CMMG
    3. Barrel extensions... N/A or US made thread adaptor
    4. Mounting blocks (trunions) : Not Applicable, I cannot find a trunion in diagrams and the barrel is not pressed or pinned into a fixture.
    5. Muzzle attachments - will be US made
    6. Bolts: YES, cant' change, count = 2
    7. Bolt carrier: Same part as the bolt, called the breech block in diagrams
    8. Operating rod: yes, cant change, count = 3
    9. Gas piston: N/A
    10. Trigger housings Yes, can't change, count = 4
    11. Trigger, switch to APG trigger
    12. Hammer, Yes, can't change, count = 5
    13. Sears, yes, can't change, count = 6
    14. Disconnector, not applicable, cannot find a disconnector distinct from sear
    15. Butt stock, yes count = 7
    16. Pistol grip, is integral w buttstock and is a thumbhole stock
    17. Forearm, no removable forearms or handguards, integral with the buttstock
    18. Magazine bodies, yes, count = 8
    19. Follower, count = 9
    20. Floorplate, using CMMG 30->50 conversion

    If I have an error or two, or need to count 2 sears, people please let me know what you think. If the above is valid and checks out w BATFE, it would hopefully be re-assuring to folks that you don't have to change very much to be 922r compliant in that rare little case it ever does come up.

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    FN Supporter Mark McWillis's Avatar
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    I have been involved in the creation and transfer of....many, MANY PS90 SBR's and there have been exactly zero 922 issues.
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