0694.0017.SuppStmt.082810

SUPPORTING STATEMENT
U.S. Department of Commerce
Bureau of Industry and Security
International Import Certificate
OMB Control No. 0694-0017

A. JUSTIFICATION
This is a request to extend the Office of Management and Budget approval.
1. Explain the circumstances that make the collection of information necessary.
Section 15(b) of the Export Administration Act (EAA) of 1979, as amended, authorizes the
President and the Secretary of Commerce to issue regulations to implement the EAA including
those provisions authorizing the control of exports of U.S. goods and technology to all foreign
destinations, as necessary for the purpose of national security, foreign policy and short supply,
and the provision prohibiting U.S. persons from participating in certain foreign boycotts. Export
control authority has been assigned directly to the Secretary of Commerce by the EAA and
delegated by the President to the Secretary of Commerce. This authority is administered by the
Bureau of Industry and Security through the Export Administration Regulations (EAR). The
EAA is not permanent legislation, and when it has lapsed due to the failure to enact a timely
extension, Presidential executive orders under the International Emergency Economic Powers
Act (IEEPA) have directed and authorized the continuation in force of the EAR.
The United States and several other countries have undertaken to increase the effectiveness of
their respective controls over international trade in strategic commodities by means of an Import
Certificate procedure.

2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
The requirements for this collection are fully described by 15 CFR Section 748.10 and Supp. 5 to
Part 748.
This collection of information utilizes Form BIS-645P, International Import Certificate for the
procedure. For the U.S. importer, this procedure provides that, where required by the exporting
country with respect to a specific transaction, the importer certifies to the U.S. Government that
he/she will import specific commodities into the United States and will not reexport such
commodities except in accordance with the export control regulations of the United States.
The U.S. Government, in turn, certifies that such representations have been made.
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This procedure involves the following steps:
a. The foreign exporter of a controlled commodity advises his/her U.S. importer that the
U.S. Import Certificate is required.
b. The U.S. importer obtains the Form BIS-645P, International Import Certificate from BIS.
c. The U.S. importer completes the form (3 copies) and returns it to BIS for review and
certification.
d. After approval and certification, two copies are returned to the importer to transmit one to
the foreign exporter; the second copy is retained by the applicant; and the third copy is
retained in BIS files. Comparable procedures with respect to exports from the United
States are followed by the other countries.
If these collections of information were not conducted there would be less control of where
strategic commodities are destined for import to the U.S. or exported from the U.S. These
controls are vital for assuring that these commodities are not diverted to unauthorized end-users
or to prohibited destinations.
The confirmation copies maintained by BIS and the foreign governments provide an investigative
reference source in cases of alleged export violations. Moreover, this requirement is mandated
by the agreement with other Import Certificate procedure participating countries to mutually
exercise controls of exports and imports of commodities controlled for reasons of national
security.
The Section 515 Information Quality Guidelines apply to this information collection and comply
with all applicable information quality guidelines, i.e., OMB, Department of Commerce, and
specific operating unit guidelines.

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
The BIS-645P is available as a form-fillable PDF on the BIS web site at:
http://www.bis.doc.gov/licensing/bis-645p_fillable.pdf
Note: The Department of State has developed a new form for their use and has requested that
Commerce revise the BIS-645P to remove State references from this form. BIS staff has
encountered a number of technical problems while attempting to revise the electronic formfillable instrument. BIS intends to publish the new form as soon as these technical problems are
resolved.
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4. Describe efforts to identify duplication.
This collection is not duplicated elsewhere. The respondents are U.S. importers who provide
information related to specific commodities exported to the U.S. by foreign exporters.
This information is not available from any source other than the respondent.

5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This collection of information must be adhered to by all U.S. importers regardless of size.

6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
If the collections were conducted less frequently violations of the EAA and the EAR would
increase to the detriment of international security interests. Anything less than a full collection
would not provide the necessary controls over international trade in strategic commodities.

7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
There are no special circumstances that require the collection to be conducted in a manner
inconsistent with the guidelines in 5 CFR 1320.6.

8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
The notice requesting public comment was published in the Federal Register, on May 21, 2010,
Vol. 75, pages 28550-28551. No comments were received.

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
Not applicable.
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10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Section 12(c) of the EAA provides for the confidentiality of licensing information submitted to
the Department of Commerce.

11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
There are no questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.
This collection of information consists of approximately 195 responses annually, based on
calendar year 2009 data. The average time of 15 minutes for preparing each response, plus one
minute each for recordkeeping, the annual burden for this collection is 52 hours.
Responses -195 @ 15 minutes each =
49
Recordkeeping -195 @ 1 minute each =
3
TOTAL 52

hours
hours
hours

The annual cost to the respondents is estimated to be $1,560. This is based on an average cost of
$30 per hour.

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in
Question 12 above).
Not applicable.

14. Provide estimates of annualized cost to the Federal government.
The total annual cost to the Federal Government is estimated to be $2,500. This based on
5 minutes to process each of the 195 certificates at an average salary of $30 per hour.
The total cost also includes approximately $2,000 per year for the equipment used for certifying,
mailing, and filing the data.

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15. Explain the reasons for any program changes or adjustments.
The adjustment is a decrease of 145 responses and 39 burden hours. The decreases may be the
result of less U.S. imports of high technology items from foreign producers.
The cost burden decrease is to remove the labor cost mistakenly included in previous submission.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
There are no plans to publish this information.

17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
BIS is seeking approval to not display the expiration date for OMB approval of the information
collection because the collection is perpetual in nature and the paper form is typically in
circulation worldwide. To have the form reprinted each time the OMB authorization changes
serves only to make otherwise good forms become obsolete.

18. Explain each exception to the certification statement.
Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.

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