Rocis 1651-0013 Ss 2019

ROCIS 1651-0013 SS 2019.doc

Entry and Manifest of Merchandise Free of Duty, Carrier's Certificate and Release

OMB: 1651-0013

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Supporting Statement

Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate of Release

1651-0013

A. Justification:


  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


CBP Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate of Release, is used by carriers and importers as a manifest for the entry of merchandise free of duty under certain conditions. CBP Form 7523 is also used by carriers to show that articles being imported are to be released to the importer or consignee, and as an inward foreign manifest for vehicles weighing less than 5 tons arriving from Canada or Mexico with merchandise conditionally free of duty. CBP uses this form to authorize the entry of such merchandise. CBP Form 7523 is authorized by 19 USC 1433, 1484 and 1498. It is provided for by 19 CFR 123.4 and 19 CFR 143.23. This form is accessible at http://www.cbp.gov/newsroom/publications/forms?title=7523&=Apply.


2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The information collected on CBP Form 7523 is used by CBP to authorize the entry of merchandise that is free of duty in accordance with regulations.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

This form can be submitted electronically via the Document Image System into ACE.


4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.


This information is not duplicated in any other place or any other form.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


This information collection does not have an impact on small businesses or other small entities.


6. Describe consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.


The consequence to the Federal program if the information were collected less frequently would be that cargo control and accountability would be compromised.

7. Explain any special circumstances.


This information is collected in a manner consistent with the guidelines of 5 CFR 1320.6.


8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Public comments were solicited through two Federal Register notices including a 60-day notice published on September 24, 2018 (Volume 83, Page 48321) on which no comments were received, and a 30-day notice published on December 26, 2018 (Volume 83, Page 66292) on which no comments have been received.


9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


There is no offer of a monetary or material value for this information collection.


10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

A PIA for the Automated Commercial Environment (ACE), dated July 31, 2015, and a SORN for IIS, dated July 26, 2016 (Vol. 81, Page 48826) will be included in this ICR. There are no assurances of confidentiality provided to the respondents of this information collection.


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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.


12. Provide estimates of the hour burden of the collection of information.



FORM

TOTAL

ANNUAL

BURDEN

HOURS


NO. OF

RESPONDENTS

NO. OF

RESPONSES PER RESPONDENT


TOTAL ANNUAL

RESPONSES


TIME PER

RESPONSE

7523


8,247

4,950

20

99,000

5 minutes or

(.0833) hours

Public Cost

The estimated cost to the respondents is $245,430. This is based on the estimated burden hours (8,247) multiplied by (x) the average loaded hourly wage rate for importers ($29.76). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2017 median hourly wage rate for Cargo and Freight Agents ($20.11), which CBP assumes best represents the wage for importers, by the ratio of BLS’ average 2017 total compensation to wages and salaries for Office and Administrative Support occupations (1.4801), the assumed occupational group for importers, to account for non-salary employee benefits.1,2 This figure is in 2017 U.S. dollars and CBP assumes an annual growth rate of 0 percent; the 2017 U.S. dollar value is equal to the 2018 U.S. dollar value.


13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.


There are no capitalization or start-up costs associated with this collection of information. There is no recordkeeping associated with this collection of information.


14. Provide estimates of annualized cost to the Federal Government. Also provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to the Federal Government associated with the review of these records is $1,041,174. This is based on the number of responses that must be reviewed (99,000) multiplied by (x) the time burden to review and process each response (10 minutes or .1667 hours) = 16,503 hours multiplied by (x) the average hourly loaded rate for a CBP Trade and Revenue employee ($63.09)3 = $1,041,174.

15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13 of this Statement.


There has been no increase or decrease in the estimated burden hours previously reported for this information collection. There is no change in information collected.


16. For collection of information whose results will be published, outline plans for tabulation, and publication.


This information collection will not be published.


  1. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


CBP will display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement identified in Item 19,

Certification for Paperwork Reduction Act Submissions”.


CBP does not request an exception to the certification of this information collection.


  1. Collection of Information Employing Statistical Methods


No statistical methods were employed.





1 Source: U.S. Bureau of Labor Statistics. Occupational Employment Statistics, “May 2017 National Occupational Employment and Wage Estimates, United States- Median Hourly Wage by Occupation Code.” Updated March 30, 2018. Available at https://www.bls.gov/oes/2017/may/oes_nat.htm. Accessed June 11, 2018.

2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2017 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Office and Administrative Support occupations ($26.2600) divided by the calculated average of the 2017 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category ($17.7425). Source of total compensation to wages and salaries ratio data: U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation. Employer Costs for Employee Compensation Historical Listing March 2004 – March 2018, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2018 by respondent type.” March 2018. Available at https://www.bls.gov/web/ecec/ececqrtn.pdf. Accessed June 11, 2018.

3 CBP bases this wage on the FY 2018 salary and benefits of the national average of CBP Trade and Revenue positions, which is equal to a GS-13, Step 3. Source: Email correspondence with CBP’s Office of Finance on June 1, 2018.

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