i'm not sure but i don't think so because i have seen "pre ban" hi cap 10/22 mags for sale at local stores. if it didn't matter why would they label them pre ban? i went to a gun store once and asked why the new ruger 22 ar-15 type had a collapsible stock and the guy behind the counter said because it was a 22. so his statement supports that it is exempt but i think he was wrong.