Form 6A justification

DEPARTMENT OF JUSTICE

BUREAU OF ALCOHOL, TOBACCO, FIREARMS AND EXPLOSIVES

Supporting Statement

1140-0007

Release and Receipt of Imported Firearms, Ammunition and Implements of War

ATF F 6A (5330.3C)

1. Justification

1. Under 18 U.S.C. 925(a), 22 U.S.C. 2778, and 26 U.S.C. 5844, the importation of firearms, ammunition and defense articles into the United States is restricted. The importation of articles coming within the purview of these statutes is prohibited. The statutes also require that persons engaged in the business of importing such articles be licensed and/or registered. Implementing regulations in 27 CFR Parts, 447, 478, and 479 prescribe the forms and procedures necessary to fulfill the import permit requirements. Through these requirements, the law and regulations establish a comprehensive system for regulating the importation of firearms, ammunition, and defense articles.

The Form 6A has been changed. The changes include:

1) Item #4 was amended to require the respondent to record their AECA number in this block. AECA registered only importers are required to complete the Form 6A and previously they were not able to record their registration number on the form.

2) Item #5 was amended to include the word “Required”. This information was often left blank by the importer and is required to process this form.

3) Item #6 was amended to add the word “Required”. This information was often left blank by the importer and is required to process the form. 4) Item #9 was amended to reflect Item #8 on the Form 6. Importers often failed to complete this section properly and we felt that by having a separate block for each item of required information that it would ensure the form was completed properly.

2. The data provided by this information collection request are used by the Bureau to determine if articles imported meet the statutory and regulatory criteria for importation and if the articles shown on the permit application have actually been imported. The Release and Receipt of Imported Firearms, Ammunition and Implements of War, ATF F 6A (5330.3C) serves as the certification of release and receipt of the articles described on the permit application. The form is used by Federally licensed and/or registered importers, Federal firearms licensees other than importers, members of the U.S. Armed Forces and persons not licensed by or registered with ATF.

3. ATF F 6A (5330.3C) is available on the ATF website but cannot be submitted electronically. The respondent must present this form to U.S. Customs and Border Protection (CBP) with an original signature and the CBP official should complete Section II of this form and certify with an original signature if he is satisfied that the shipment of firearms(s), ammunition, and/or implements of war was authorized by the Director, ATF. The form must be mailed back to ATF. Future plans for this form involve full electronic submission that would have to be coordinated with CBP and ATF would need to have the capability to accept electronic submissions.

4. ATF uses a subject classification system to identify duplication and to ensure that any similar information already available cannot be used or modified for use for the purpose of this information collection.

5. This information collection has no impact on small businesses.

6. The consequences of discontinuing the requirement for ATF F 6A are that licensed importers, dealers, and military personnel would be unable to import firearms, ammunition, and implements of war as allowed by statute. Shipments would be detained by CBP resulting in unnecessary expense to the industry. Less frequent collection of this information would substantially increase the potential possibility for the illegal introduction into domestic commerce of firearms, ammunition, and implements of war. This would pose a threat to public safety by exacerbating crime and violence and undermining the declared law enforcement, foreign policy, and revenue purposes of 18 U.S.C. 925(a), 22 U.S.C. 2778, and 26 U.S.C. 5844.

7. This information collection is conducted in a manner consistent with the guidelines of 5 CFR 1320.6.

8. This information collection is mandatory by law however ATF did consult with CBP in the development of this form. A 60-day and 30-day notice was published in the Federal Register in order to solicit comments from the public. No comments were received.

9. No payment or gift is associated with this information collection.

10. Disclosure of the information by the applicant is mandatory for the release and receipt of imported firearms, ammunition, and implements of war. The information is kept in a secured location. Confidentiality is not assured.

11. No questions of a sensitive nature are asked.

12. There are 20,000 respondents who complete this form. Each respondent completes the form 1 time. The total number of annual responses is 20,000. Estimated time to complete this form has increased from 24 minutes to 35 minutes. The total burden associated with this form has increased from 8,000 hours to 11,667. The adjustment is a difference of 3,667.

13. There is no start-up cost associated with this collection. The cost to the respondent is postage which is estimated at $8,800.

14. Estimates of annual cost to the Federal Government are: Printing, $2,200 and Labor $42,000 for a total of $44,200.

15. The adjustments in burden are the result of an increase in the time it takes to complete the form.

16. The results of this collection will not be published.

17. ATF does not request approval to omit the expiration date of OMB approval for this information collection.

18. There are no exceptions to the certification statement.

2. Collections of Information Employing Statistical Methods

This information request does not employ statistical methods.

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