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I have been doing some research into the legalities of putting a vertical foregrip on a pump 12ga shotgun, which already has a birds head grip and which never had a stock. I have seen that it makes a big difference if the barrel is under or over 18", the former classifying the weapon as a "firearm" and the latter classifying the weapon as a "shotgun", each with their own lists of permissible and NFA results.

But check this excerpt from an ATF open letter -The Streetsweeper, Striker-12, and the USAS-12 shotguns Destructive Devices?

https://www.atf.gov/firearms/docs/o...tration-period-streetsweeper-striker/download

Obviously we all want to steer clear of this...

From what I can tell, putting a vertical fore grip on a legal length pump shotgun, which never had a stock attached to the receiver before, is at best "sketchy".

Would an angled foregrip be a better bet?
 
The streetsweaper et. al. were reclassified as destructive devices based on their larger than .5in bore diameter and having "no sporting purpose." This was a purely political decision, banned the firearms by name and impacts no other makes or models. Hell, you could design a functional clone of any of these and they would get the default sporting exemption of all new 12 gauges and would be perfectly legal until the ATF got off their bubblegum and issued a new letter covering your "new" design.

As long as your shotgun is longer than 26 inches and barrel longer than 18 inches you are fine, it is still a plain vanilla shotgun and you can put whatever type of foregrip on it you want (or add a stock if you so wish).

If you are longer than 26 inches, but with a barrel shorter than 18 inches you have an undefined "firearm" that is not an NFA item. If you put a vertical foregrip on that you have made an AOW and that is covered under the NFA. That is a $5 transfer stamp (or $200 if you want to make it yourself, best to buy an AOW if you want one). VFGs are only legal with no stamp on "properly defined" long arms, so recognized "shotguns" or "rifles," or on any properly registered NFA item. Since this falls into no defined category it gets to be its own thing. The ATF has not released a whole lot of letters or guidance on the topic, be careful if you are treading here; there be dragons.

If you have a shotgun shorter than 26 inches, with a barrel shorter than 18 inches and no stock you have a designated AOW. You can put a VFG on one of these as it is already a AOW and the stamp covers the VFG as well as the short smooth bore/no stock thing. I am pretty sure this also covers shotguns shorter than 26 inches with barrels longer than 18 inches. I cannot think of any other category they would fall under.

If you have a barrel shorter than 18 inches and a stock you have a short barreled shotgun, and over all length is irrelevant. You also have a SBS if your OAL is shorter than 26 inches and you have a stock, and barrel length is irrelevant (this is a harder configuration to pull off, but I put it here for completeness). VFGs are also permissible on any of these because, again, the stamp already covers it.

Hope that helps.
 
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