Form 6 Part I justification

DEPARTMENT OF JUSTICE

BUREAU OF ALCOHOL, TOBACCO, FIREARMS AND EXPLOSIVES

Supporting Statement

#1140-0005

Application and Permit for Importation of Firearms, Ammunition, and

Implements of War, ATF F 6 (5330.3A) Part I

1. Justification

1. Importation of firearms, ammunition, and defense articles into the United

States is subject to the provision of 18 U.S.C. 925(d) and (e), 22 U.S.C. 2778,

and 26 U.S.C. 5844. Except as provided, or specifically authorized by the

Attorney General, the importation of articles coming within the purview of

these statutes is restricted or prohibited. In general, the importation of firearms

is permitted only if the firearms meet certain criteria and the Attorney General

authorizes the importation.

The form was amended. The changes include the following:

FOR APPLICANTS OPTIONAL USE 1) The “optional number” block was deleted and the “internal control #” was amended to state “internal control/reference #”. A block was also added to allow an importer to record their email address.

SECTION I 1) Item #1 was amended to reflect the correct sequencing of the FFL number.

2) Item #2 was amended to prompt the importer to add their extension (if applicable) to their phone number.

3) Item #8a. Importers often add attachment sheets when the space provided for on the form proves to be insufficient. Often these attachment sheets lack all of the required information. Consequently, we have now provided attachment sheets for each section and added a checkbox for the importer to indicate if the attachment sheet(s) were used.

Firearms section: 4) Item 8b was amended to include the additional descriptors for frames and receivers.

5) Item #8e was amended to include “U.S. Currency”.

6) Item #8f was amended to correctly state “U.S. Munitions Import List Category.” 6) Item #8g was amended to delete “(MFRS) design” to encourage importers to give us the model designation. This information is necessary to determine if a firearm is sporting and therefore importable.

7) Item #8h was amended to include “inches” to the descriptor “length of barrel.”

8) Item #8i was amended to include “inches” to the descriptor “overall length”.

Ammunition section: 9) Item #8b was amended to include the descriptors “AP” and “Tracer”.

10) Items #13-15 were amended to now require the applicant to both print and sign their name. The numbering on the form was adjusted accordingly.

SECTION II: 1) item 17 was amended to add the “no permit required” to the types of action taken by ATF. INSTRUCTION PAGE: 1) All references to Customs were changed to U.S. Customs and Border Protection (CBP) as appropriate.

2) Item #8 was amended to include all of the requirements for importations by U.S. citizens returning to the U.S. and for non-resident aliens immigrating to the U.S. outlined on page 162 in the Federal Firearms Regulations Reference Guide.

FORMS 1) Item #24 was amended to reflect the correct retention period of the form and to correct the address of the Distribution Center.

2. The data provided on ATF Form 6 (5330.3A) Part I, Application and Permit for

Importation of Firearms, Ammunition, and Implements of War is to allow ATF

to determine if the article(s) described on the application qualifies for

importation by the importer, and to serve as the authorization for the importer.

The approved form also serves as the authorization to U.S. Customs and Border

Protection (CBP) to allow the listed articles entry into the United States. Many

importers use the form for internal accounting purposes.

Additionally, information may be disclosed to other Federal, State, foreign,

and local law enforcement and regulatory agency personnel to verify

information on the application and to aid in the performance of their duties

with respect to the enforcement and regulation of firearms and/or ammunition

where such disclosure is not prohibited by law. The licensee is required to

retain this form permanently.

3. The form is available on the ATF website www.atf.gov and it is fillable but it can’t be submitted electronically. The eform 6 captures the same information and it can be submitted electronically at http://www.atf.gov/applications/eform6/. It is estimated that 3,000 of the respondents complete this form electronically. The remaining respondents mail the form to ATF.

3. ATF uses a uniform 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.

3. ATF does not use any method to minimize the burden to small business since all entities, regardless of size, are required by statute to complete this form.

3. The consequence of not conducting this information collection would result in persons illegally importing firearms, ammunition, and implements of war into the United States. This form serves as authorization to import such articles.

3. There are no special circumstances as this information collection is conducted in a manner consistent with 5 CFR 1320.6.

3. The ATF industry analyst who is very aware of the needs of the import community was involved during the creation of this form. A 60-day and 30-day Federal Register notice was published in order to solicit comments from the general public. No comments were received.

3. No decision of payment or gift is associated with this collection.

3. Federal firearms licensees keep this information in locked files in a secured location. Confidentiality is not assured.

3. No questions of a sensitive nature are asked.

3. The number of respondents associated with this collection is 11,000. Each respondent completes the form one time. The total number of responses is 11,000. The time necessary to complete the form is 30 minutes. The total annual burden is 5,500.

3. The respondents that do not file electronically must mail the form to ATF. Therefore, the cost to the respondents who choose not to file electronically is postage. Of the 11,000 respondents that complete the form, 3,000 file electronically. The postage cost is based on 8,000 respondents x .44 = $3,520.00.

3. Estimates of annual cost to the Federal government is the printing of forms that are stocked at the ATF Distribution Center for respondents who choose to mail the form:

Printing $5,000.00

3. The revised changes include clarification changes to information that was already on the form. Also, if a block was deleted, a block was added. Additional attachments were added to give the importers more space. These attachment sheets are duplicates of the same information. For this submission, the program office responsible for this collection is not increasing the time it takes to complete the form. The form will be closely monitored and if needed, adjustments will be made to the burden.

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

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

3. 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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