Beretta neos u22 Carbine

Craig Packer

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I searched the forums hoping to find some conversations about the kit that changes the Neos pistol into a rifle. Are they that elusive?
 

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yes
they didn't make all that many, and they advertised that you could turn your pistol into a rifle, but refused to say whether or not you could legally turn it back into a pistol.
You can find the kits on armslist or gun broker from time to time, but you're looking at 300 or more just for the stock and barrel, gun receiver not included.

It's on my list of things to get one of these days. but i got other things that come before it.
 
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Found this in my Neos notes...

Beretta has not discontinued the U22 Carbine Conversion Kit (Part JU22CK1). Beretta and the BATFE have not reached an agreement as to how to sell the U22 Carbine Kit as, under current Federal (and many State) Firearm Regulations, a pistol (such as the U22 NEOS) can not be converted into a rifle unless it is registered as a separate firearm. Under current BATFE Federal firearm regulations, an owner of a U22 NEOS would have to re-register the gun as a rifle. Under some State laws (such as California & New York), it would be considered an assault rifle (because of its 16" barrel length) and would not be able to be sold in those States.
 
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Additional comments from my Neos notes...

I think some of the questions to ask are "does the Beretta 'kit' meet the criteria specified in the ATF letter?" and "what is ATF definition of a 'single source'?"

If accurate that the NEOS kit contains a shoulder stock only and a +16" barrel only then it does not appear to meet the ATF definition of a kit. Then move to the "single source" issue - what is that specifically? The same store, the same distibutor or just the same manufacturer? Is a "kit from the same source" a single purchase of all items at once or can it be from the same manufacturer over a period of time? A strictest interpretation of the kit and single source requirement could be buying all the parts specified by ATF at the same time as a complete kit. The loosest interpretation might be buying all the parts from the same "source" (meaning manufacturer) over a period of time. I don't know the answer.

We then have to deal with the ATF requirement of the receiver not being previously assembled as a handgun or a long gun. According to the ATF letter if one purchases a NEOS frame but does not assemble it as a handgun first - they're fine. If one purchases a NEOS already assembled as a handgun - not fine.

Regarding the "a company would be too careful and not do this" I'd like to think so too. Makes sense to me they would know what to do and not do, big $$$ and PO'd customers are on the line. It would be interesting to get their take on the ATF letter. One could interpret Beretta's responses to the questions already posted to mean "if the frame was purchased as a handgun with the barrel not attached and if one purchased our "kit" at the same time you can switch back & forth between handgun and long gun". I don't think they wrote anything contrary to that strict interpretation, but that's not exactly answering the questions in a most helpful manner.

I think the scenario gets complicated & requires precisely worded questions & follow up for accurate and complete answers. I think an "all in one" complete single source kit complies with the criteria in the ATF letter allowing back & forth switching. As one strays from that all in one complete single source kit - I think it becomes more difficult to give a certain answer. I think separately buying a NEOS handgun a few years back, then separately buying and attaching the NEOS carbine kit, does not appear to meet the criteria specified in the ATF letter. That's just my layman's read of the thing.
 
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Under this "kit" interpretation, one could never convert an AR pistol into a rifle and then back, but we know that's perfectly legal. You can even buy glock carbine conversion kits to turn your pistol into a rifle and back.
Your post from neos notes or whatever has to be from that strange time when the ATF had no idea what they were doing (specific, right) but I'm guessing 2010ish. I think that's about the time it all got weird and the stock of kits dried up. And a year later, ATF clarified that this sort of thing is legal according to US v Thompson Center Arms

Therefore, so long as a parts kit or collection of parts is not used to make a firearm regulated under the NFA (e.g., a short-barreled rifle or “any other weapon” as defined by 26 U.S.C. 5845(e)), no NFA firearm is made when the same parts are assembled or reassembled in a configuration not regulated under the NFA (e.g., a pistol, or a rifle with a barrel of 16 inches or more in length).

I don't want to get into the wisdom of putting gun-ignorant people in charge of makign policies on a whim that carry the weight of law... but...
 
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