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Steven, the ultimate authority would be the ATF- you could write them and see what they have to say. The usual concern with swapping stocks and magazine tubes on standard M4's is 922(r) compliance, not sure how this one would be handled since it already has both installed. As for not being available for special order, that is probably because this model is discontinued. https://www.atf.gov/contact
Steven, No special orders because this firearm is no longer made. Benelli M4 Tactical Shotgun 12ga, h20, barrel 18.5" barrel 11711 , ... This item is discontinued. Sorry! This product has been discontinued.
Steven, I would think Benelli would be the Authoritative source as to the classification of this Shotgun. Just saying my man.