Supporting Statement A

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U.S. Environmental Protection Agency 
Information Collection Request
EXECUTIVE SUMMARY
Identification of the Information Collection – Title and Numbers
Title:
Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides 
EPA ICR No.:
0161.17
OMB Control No.:
2070-0027
Docket ID No.:
EPA-HQ-OPP-2021-0749
Abstract
This information collection request (ICR) addresses the information collection activities associated with the requirement that the Environmental Protection Agency (EPA) receive notice when unregistered pesticides are exported from the United States to foreign purchasers. This statement is to ascertain the purchasers’ understanding that the pesticide product cannot be sold in the United States. Section 17(a)(2) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (Ref. 1) requires an exporter of any pesticide not registered under FIFRA Section 3 or sold under FIFRA Section 6(a)(1) to obtain a signed statement from the foreign purchaser acknowledging that the purchaser is aware that the pesticide is not registered for use in, and cannot be sold in, the United States. A copy of this statement, which is known as the Foreign Purchaser Acknowledgement Statement (FPAS) must be transmitted by EPA to the designated national authority or appropriate official of the government in the importing country. This information is submitted via mail or electronically through a Salesforce based application called MyPest, in the form of annual or per-shipment statements. EPA maintains original records and transmits copies, along with an explanatory letter, via email to appropriate government officials of the countries that are importing the pesticide.
In addition to the export notification for unregistered pesticides, FIFRA requires that all exported pesticides include appropriate labeling. There are different requirements for registered and unregistered products. For registered products, export labeling requirements alone meet the definition of third-party notification. In the interests of consolidating various related information collection requests, this ICR includes burden estimates for the FPAS requirement for unregistered pesticides, as well as the labeling requirement for all exported pesticides, both registered and unregistered. These burdens have been consolidated in this ICR since the implementation of the 1993 pesticide export policy governing the export of pesticides, devices, and active ingredients used in producing pesticides.
Summary Total Burden and Costs
Information Collection
Number of Respondents
Annual Number of Responses
Responses per Respondent
Annual Time Burden (Hours)
Annual Cost Burden (Dollars)
Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides
100
1,951
20
2,114
$148,339
Labeling for Unregistered Exported Pesticide Products
100
488
5
3,904
$299,352
Multilingual Product Labeling for Registered Exported Pesticide Products
100
1,463
15
8,047
$580,968
Total Respondent
100
3,902

14,065
$1,028,659
Total Agency 



680
$58,275
Note: All values in table subject to rounding.
SUPPORTING STATEMENT A
    1. NEED AND AUTHORITY FOR THE COLLECTION:
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
This information is required to be submitted to EPA pursuant to FIFRA Section 17(a)(2). Regulations pertaining to pesticide export are in 40 CFR Part 168, Subpart D (Ref. 3).
Pursuant to 40 CFR 168.85, the FPAS must contain the following information:
    1. Name and address of the exporter.
    2. Name and address of the foreign purchaser.
    3. Name of the product and active ingredient.
    4. Statement that the foreign purchaser is aware that the product is not registered for use in the United States and cannot be sold for use in the United States.
    5. If known, the country of final destination of the exported shipment if different from the country of import.
    6. Signature of the foreign purchaser.
    7. Date that the purchaser acknowledgment statement is signed by the foreign purchaser.
    8. Certification that the shipment did not occur prior to receipt of the Purchaser Acknowledgment Statement.
    9. Exporter’s signature.
In addition to FPAS, pesticide product exporters are also subject to third party notification requirements for both registered and unregistered pesticides. All exported registered pesticides must bear the EPA-approved label and supplemental labeling options made to accommodate the importing country’s requirements. For unregistered pesticides, the following information must be included on the labels or labeling:
    1. EPA pesticide producing establishment number.
    2. Warning or caution statements.
    3. The statement “Not Registered for Use in the United States of America.” The labels of all pesticides, devices, and active ingredients which are not registered for use in the United States under FIFRA section 3 must include the “Not Registered for Use in the United States of America” statement.
    4. The ingredient statement.
    5. Identity of parties.
    6. Weight or measure.
    7. Additional warning for highly toxic pesticides.
    8. Use classification statement.
For both registered and unregistered products, the following labeling information must be multilingual:
    1. Warning and caution statements.
    2. Where applicable, the statement “Not registered for use in the United States of America.”
    3. Ingredient statement.
If the pesticide, device, or active ingredient is highly toxic to humans, a skull and crossbones, the word “Poison,” and a statement of practical treatment must appear on the label. The word “Poison” and statement of practical treatment shall be in English and in an acceptable language of the country of import, and in an acceptable language in the country of final destination, if known or reasonably ascertainable.
2. PRACTICAL UTILITY/USERS OF THE DATA: 
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.
Section 17(a)(2) of FIFRA requires all exporters of unregistered pesticides to obtain signed statements from their purchasers acknowledging that they are aware that the purchased products are not registered in the United States. Hence, one use of this collection activity is in confirming that foreign purchasers of pesticides produced in the U.S. are aware of the products’ U.S. registration status. When such statements are submitted to EPA, the Agency is provided with a record of foreign destinations of domestically produced unregistered products. This enables the Agency to assure that such products, which are produced in the U.S. but cannot be legally sold for use in the U.S., have been legally distributed.
In addition, such statements are required by statute to be directed onward to the appropriate government officials in importing countries. Foreign government officials can use this information to verify that a specific pesticide product, that may or may not have an active ingredient that has been evaluated by EPA and approved for registration, has been exported to their country. The name and address of the purchaser in the importing country is included, enabling the government official to contact the purchaser directly, as appropriate. This information can be useful in countries that do not have the resources to maintain extensive import records or control systems.
3. USE OF TECHNOLOGY: 
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.
Beginning in 2012, EPA began transmitting the FPAS electronically to Designated National Authorities (DNAs) identified by the Rotterdam Convention on Prior Informed Consent for Certain Hazardous Chemicals and Pesticides in International Trade where a valid email address exists and through mail where one does not. EPA has determined that sending the FPAS, which may contain FIFRA sensitive information, through the mail or via electronic media to foreign governments pursuant to FIFRA Section 17 is acceptable for the following reasons: 1) The transmission is a limited, non-public disclosure required by FIFRA; 2) Foreign recipients are not subject to FIFRA security procedures in the FIFRA Information Security Manual; 3) The specific recipient in the government of the importing country is often not known. Both mail and electronic transmissions include a cover with the following language: “This Purchaser Acknowledgement Statement may contain information claimed as confidential. Please treat the statement according to appropriate national confidentiality laws and regulations.”
Information collected under this ICR is currently submitted to EPA by mail or electronically. An electronic option was announced on August 18, 2021 (86 FR 46246 (FRL-8721-01-OCSPP)) to allow for COVID-19 flexibilities. Recently, EPA developed a new electronic submission system via Salesforce, called MyPest, for exporters to submit FPAS documents. The new MyPest system was available for users beginning July 2026 and provides better customer experience (Attachment A).
4. EFFORTS TO IDENTIFY DUPLICATION:
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.
For every export of an unregistered pesticide, the U.S. exporter is required to obtain the FPAS prior to export and certify to EPA that export did not occur prior to the exporter’s receipt of the FPAS. The FPAS and the certification statement must then be transmitted to the governments of importing countries. EPA is not aware of any other collection requirements for this information. 
EPA recognizes that repeated submissions of purchaser acknowledgment statements involving the same country, purchaser, and pesticide product would be duplicative and potentially burdensome. Individual submissions do, however, provide information on the total number of shipments to a specific purchaser. For this reason, EPA offers an option to exporters to either make individual submissions for every export, or to notify EPA upon the first export to the foreign purchaser and then provide an annual summary of all shipments no later than March 1 of the following calendar year. This reduces the redundancy that would be associated with the submission of identical acknowledgment statements by the same purchaser for the same product, while still providing EPA and foreign governments information regarding the number of shipments in the previous calendar year.
5. MINIMIZING BURDEN ON SMALL ENTITIES:
 If the collection of information impacts small businesses or other small entities, describe the methods used to minimize burden.
Under this reporting requirement, small entities must follow the same collection procedures as large companies. Both large and small entities may avail themselves of options which support alternative, flexible means of meeting specific requirements:
    1. Reporting options
    2. Acquisition options
    3. Formatting options of required information. 
The Agency allows respondents the choice of reporting options; respondents can choose between annual estimates and summaries or per-shipment statements. Respondents are also allowed flexibility in determining the method of obtaining the foreign purchaser acknowledgment statement. Finally, EPA provides flexibility in the formatting of submissions; small entities and occasional submitters may find it easier to comply with the requirements since they do not have to adhere to a specific format.
6. EFFECTS OF LESS FREQUENT COLLECTION:
Describe the consequence 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.
By offering the compliance option of annual reporting, EPA is offering a less frequent information submission to reduce the burden of per-shipment reporting. Further reduction, i.e., to a one-time submission for the life of the product or otherwise to a frequency of less than once a year could compromise the accuracy of the data on the number of shipments exported to a particular purchaser in another country. Less frequent submission could also make it difficult for foreign governments to determine the regulatory status of imported pesticides.
The annual summaries provide EPA with the ability to monitor compliance with the requirements of FIFRA section 17(a). Currently, such records must be retained by exporters for only two years. Since the summaries are submitted after the applicable year, less frequent submissions could result in the unavailability of records necessary to validate submissions.
    7. GENERAL GUIDELINES:
 Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
There are no special circumstances. The collection of information is conducted in a
manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

    8. PUBLIC COMMENT PERIOD AND CONSULTATIONS:
8a. Public Comment
 If applicable, provide a copy and identify the date and page number of publication(s) 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 in response to the comments. Specifically address comments received on cost and hour burden. 
Pursuant to 5 CFR 1320.8(d), EPA published a notice in the Federal Register on December 15, 2025 (90 FR 57999; FRL-12889-01-OCSPP), announcing the planned renewal of this information collection activity, soliciting public comment on specific aspects of the ICR and providing a 60-day public comment period. No comments were received. 
8b. Consultations
Describe efforts to consult with persons outside EPA 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 report. 
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
The EPA also consulted five stakeholders, specifically asking them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR (Attachment B). The stakeholders consulted were:
    1) FMC Corporation
    2) Koch Agronomic Services LLC
    3) Kocide LLC
    4) Neogen Corporation
    5) Syngenta
Of those consulted, EPA received no comments.
9. PAYMENTS OR GIFTS TO RESPONDENTS:
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. 
No payments or gifts are provided to respondents.
    10. PROVISIONS FOR PROTECTION OF INFORMATION:
 Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
EPA urges submitters to minimize the amount of claimed Confidential Business Information (CBI). All data and/or information submitted to the Agency under this information collection that may be claimed as trade secret, commercial, or financial information will be protected from disclosure by EPA under FIFRA section 10.
Based on “Non-confidentiality of Certain Information Submitted under Sections 7 and 17(a)(2) of FIFRA”, 55 FR 1261 (January 12, 1990) and “Class Determination 1-91, Identity of Importing Country Under FIFRA Section 17(A)(2)”, 58 FR 9062 (February 18, 1993), the following information will generally not be considered confidential: (a) The fact that a producer makes a registered or unregistered pesticide product; (b) the fact that an acknowledgement statement or other notice of export has been filed by an exporter; (c) the identity of the unregistered exported product; and, if applicable, the identity of the active ingredients of the pesticide; and (d) the identity of the importing country and the country or countries of final destination. According to statute, this same information must be reported to the government of the importing country.
Exported research and development substances that fit the criteria set out in 40 CFR 168.75(b)(5) are not subject to the FPAS requirement but are subject to the labeling requirement. CBI may be required to be submitted in the case in which a business wishes to export an unregistered research pesticide product that does not fit the criteria of 168.75(b)(5). EPA recognizes that the chemical identity of the research product may require protection as confidential business information but believes that it is essential that the Agency nevertheless be able to accurately identify the nature of the product. The identity of a product under research and development may be identified by use of identification codes which protect proprietary information. If the submission contains confidential business information, it must include the phrase “confidential for research purposes” and a sanitized version must be submitted for transmission to the appropriate foreign government.
Records supporting research and development status must include information regarding research intent of the shipment as well as information indicating knowledge that the quantity being shipped is consistent with research intent, as specified in 40 CFR 168.75 (b)(5). Persons claiming an exemption from the FPAS requirement for the export of research and development products must maintain records which support this claim for each shipment so claimed. In its policy, EPA has limited research claims only to shipments where the quantity shipped would be unlikely to support a commercial use. Thus, the company’s records must be sufficient to support the claim that the quantity shipped is only sufficient for use within the limits of the policy. This can be done either in the form of communications received from the purchaser before or on the date of export or in the form of instructions sent to the purchaser before or on the date of export.
Alternatively, the exporter may retain records which indicate that the quantity shipped is compatible with the claim that the amount can only be used as provided in the policy. Such information could include test results, literature citations, or other information which supports the claim.
At the time of shipment, the exporter must maintain a record of the identity, amount, and date that the pesticide was shipped, the destination and purchaser, and the intended research use. Most of this information is typically reflected on invoice/shipping records normally maintained for such products; records of pesticide shipments are already required to be maintained under FIFRA section 8. Other documentation supporting research use is generally available as typical business practice and should not impose additional burdens. Records of shipment and confirmation of research intent must be maintained and made available for inspection and copying by EPA for two years following the export of the pesticide.
11. JUSTIFICATION FOR SENSITIVE QUESTIONS:
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.
The information collection activities do not include questions of a sensitive nature.

12. RESPONDENT BURDEN HOURS AND LABOUR COSTS:

Provide estimates of the hour burden of the collection of information.
    • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.
    • If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens. 
    • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
12a. RESPONDENTS/NAICS CODES
Respondents in this ICR are individuals or entities that either manufacture and export pesticides, or that reformulate or repackage and export pesticides.
NAICS Code
Description
325
Chemical Manufacturing
Includes: 3251, 3252, 3253 and 3259

12b. INFORMATION REQUESTED
The requirements to be fulfilled under this ICR consist of two parts: submission of FPAS and third-party notification export labeling requirements. The third-party labeling requirement is further subdivided into labeling requirements for unregistered exported pesticide products and multilingual labeling requirements for both registered and unregistered exported pesticide products. 
Regulation requires that companies exporting pesticides not registered in the US obtain a statement from the foreign purchaser of the pesticide product for each shipment of the product. If the exporter anticipates making more than one shipment of the product to the purchaser in a given year, the exporter may elect to notify EPA only at the time of the first shipment and to comply with the annual reporting option, which requires the submission of an annual summary of shipments of pesticides shipped to each purchaser.
In addition to the export notification for unregistered pesticides, regulation also requires that all exported pesticides include appropriate labeling. For registered pesticides, this is the EPA-approved label and any supplemental labeling information necessary to accommodate the importing company’s requirement. For unregistered exported pesticides, labeling requirements are outlined in 40 CFR 168.70 and in Question 1, above. All pesticides regardless of registration status must have multilingual warning, caution, and ingredient statements in English, an acceptable language of the country of import, and an acceptable language of the country of final destination. A multilingual statement of “Not registered for use in the United States of America” must also be included on labels of unregistered pesticides.
The burden estimation for the FPAS portion includes respondents time to prepare a statement for signature by the importer or prepare instructions that are adequate to ensure the purchaser can prepare the statement. The burden estimation for the third-party labeling requirements includes respondents time to read regulations, design labels, translate labels, and complete paperwork.
Estimates of burden are based on available data as well as Agency judgement. EPA estimates the burden in terms of the time it takes for a respondent to perform a given activity in hours or in minutes, where appropriate. The burden for each activity is estimated for managerial, technical, and clerical labor and then totaled for an estimate of burden per response. The per response time estimate is then multiplied by the number of responses to determine the total annual time burden from this ICR. 
12c. RESPONDENT ACTIVITIES AND FREQUENCY
Number of Responses and Respondents

Based on the number of FPAS received by the Agency in recent years (2022 to 2024), EPA anticipates receiving an average of 1,951 notices per year. This estimate includes both per-shipment notifications and annual summary submissions. For the additional third-part labeling requirements, the Agency estimates that approximately 25% of exported pesticide products are unregistered based on the ratio of registered to unregistered products identified in received FPAS. Based on this ratio, EPA anticipates 488 responses for unregistered pesticide labeling and translation requirements and 1,463 responses for registered pesticide translation requirements.
Based on the list of companies that have submitted FPAS in the past three years (2022 to 2024), the Agency estimates that there are 100 respondents.
Respondent Activities
Submission of Foreign Purchaser Acknowledgment Statement
The exporter is required to send a copy of the purchaser acknowledgment statement to EPA within 7 days of having shipped the pesticide, along with a signed statement that the shipment did not occur prior to receipt of the purchaser acknowledgment statement. In addition, if the exporter chooses to comply with the annual summary reporting option, they must include a statement that the FPAS submitted is for the first shipment of a pesticide to a particular purchaser in a specific country for the calendar year, and that the exporter will report this information annually as required. In this case, a summary must be sent after the end of the calendar year which lists all shipments of a particular pesticide shipped to a particular foreign purchaser. It is not required for the statement to be submitted to EPA in time to enable EPA to notify the importing country prior to arrival of the pesticide.
Submission of a purchaser acknowledgment statement does not require the maintenance of any records unique to this section. All records needed to ensure and verify compliance with this requirement are required under Section 8 of FIFRA. The recordkeeping burden related to this requirement is covered under another ICR.1
12d. RESPONDENT BURDEN HOURS AND LABOR COSTS
For this ICR, the Agency values time at the fully loaded wage rate, including benefits and other overhead costs, incurred by an employer for all affected respondent groups based on publicly available data from the Bureau of Labor Statistics (BLS). The wage rate methodology uses data from each sector for an unloaded wage rate (hourly wage rate) and then calculates the loaded wage rate (unloaded wage rate plus benefits) and fully loaded wage rate (loaded wage rate plus overhead). Loaded wage rates are understood to account for the non-wage benefits that an employee receives, such as paid holiday and sick leave and/or health insurance. Fully loaded wage rates reflect non-wage and benefit costs incurred by the employer, such as overhead or equipment used by the employee. 
To represent the respondent for this ICR, the Agency uses NAICS 3250A1, Chemical Manufacturing. Managerial, technical, and clerical wages all correspond to a specific Standard Occupational Classification (SOC). This ICR uses 11-0000 Management Occupations for managerial wages, 19-0000 Life, Physical, and Social Science Occupations for technical wages, and 43-0000 Office and Administrative Support Occupations for clerical wages. EPA uses mean hourly wage data for all relevant labor types. The fully loaded hourly wage rates for management, technical, and clerical occupations for NAICS 3250A1 are $135.50, $74.28, and $51.38, respectively. Wage estimates are based on 2024 wage data.
Table 1. Respondent Labor Costs Using NAICS: 3250A1 Chemical Manufacturing
Labor Category:
Formula
Managerial
Technical
Clerical
Unloaded Hourly Rate1
 = W
$77.80 
$42.65 
$29.50 
Benefits Percentage2
Lb = B/W
45.1%
45.1%
45.1%
Benefits per hour
B = W*Lb
$35.12 
$19.25 
$13.32 
Loaded Hourly Rate
Wb = W + B = W(1+Lb)
$112.92 
$61.90 
$42.82 
Overhead Percentage3
Lo = OH/Wb
20%
20%
20%
Overhead per hour
OH = Wb*Lo
$22.58 
$12.38 
$8.56 
Fully Loaded Hourly Rate
Wf = Wb + OH
 = W + B + OH  
$135.50 
$74.28 
$51.38 
1. Data Source: U.S. Bureau of Labor Statistics, May 2024 data, https://data.bls.gov/oes/#/industry/3250A1 
NAICS 3250A1 - Chemical Manufacturing (3251, 3252, 3253, and 3259 only)
Standard Occupational Codes:   
Managerial:	11-0000, Management Occupations
Technical:		19-0000, Life, Physical, and Social Science Occupations 
Clerical:		43-0000, Office and Administrative Support Occupations 
2. Fringe benefits/wage per hour.
3. U.S. Environmental Protection Agency, EPA Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other EPA Actions, December 15, 2020, available at https://www.epa.gov/sites/default/files/2020-12/documents/epa_handbook_on_valuing_changes_in_time_use_121520_final_508.pdf. The recommended default for overhead is 20% of the loaded hourly rate inclusive of fringe benefits.

Table 2 presents the calculations for total annual costs, a breakdown of the FPAS collection activities per respondent, and the expected labor mix required for each activity. The total managerial, technical, and clerical hours are multiplied by the annual number of requests and by the fully loaded wage rates to get a total annual respondent burden of 2,114 hours and a cost of $148,339 for submitting FPAS forms where each FPAS submission has a burden of 65 minutes or 1.06 hours and a cost of $76.03.
Table 2. Respondent Burden and Cost for the Submission of FPAS
Collection Activity
Burden Minutes
Total
 
Managerial
Technical
Clerical
Minutes
Cost ($)

$135.50 
$74.28 
$51.38 


Read Regulations
5
0
0
5
11.29
Plan Activities
0
5
0
5
6.19
Gather Information
0
5
0
5
6.19
Process, compile and reveal information
0
10
0
10
12.38
Complete paperwork
0
15
15
30
31.42
Record, disclose & display information
0
0
5
5
4.28
Store, maintain and file information
0
0
5
5
4.28
Total
5
35
25
65
76.03
Annual Burden: 1.06 hours (65 minutes) x 1,951 statements = 2,114 hours per year
Annual Costs: $76.03 x 1,951 responses = $148,339 per year
1 Hourly wage rates are fully loaded wage rates based on NAICS 3250A1 – Chemical Manufacturing (3251, 3252, 3253, and 3259 only) from U.S. Dept. of Labor, Bureau of Labor Statistics, May 2024.
2 Totals may not sum due to rounding.
Export Labeling
Every exported pesticide, device, and active ingredient used in producing a pesticide must bear a label or labeling which meets the requirements of FIFRA section 17(a)(1). The specific requirements for the labeling of exported pesticides are described above. Exporters are also required to keep records of the product labeling, including the EPA registered labeling, any foreign labeling on or attached to the product when shipped, and as applicable, any supplemental labeling. The records are to be maintained in a manner that shows exactly which labels and labeling accompanied each shipment of a pesticide product to a foreign country.
Tables 3 and 4 present the estimated respondent burden for product labeling of unregistered and registered exported pesticide products. Product labeling for unregistered exported products accounts for a total of 8 burden hours, at a cost of $613.43, for each unregistered product. This equates to a total annual burden of 3,904 hours and a total annual cost of $299,352 across all unregistered products.
Table 3. Respondent Burden and Cost for Unregistered Exported Pesticide Product Labeling and Translation

Collection Activity
 
Burden Hours
Total

Managerial
Technical
Clerical
Hours
Cost ($)

$135.50/hr 
$74.28/hr 
$51.38/hr 


Read regulations
0.5
0
0
0.5
67.75
Design labels
0
2
0
2
148.57
Translate labels
0
5
0
5
371.42
Complete paperwork and store information
0
0
0.5
0.5
25.69
Total
0.5
7
0.5
8
$613.43
Annual Burden: 8 hours x 488 unregistered products = 3,904 hours
Annual Costs: $613.43 x 488 unregistered products = $299,352
1 Hourly wage rates are fully loaded wage rates based on NAICS 3250A1 – Chemical Manufacturing (3251, 3252, 3253, and 3259 only) from U.S. Dept. of Labor, Bureau of Labor Statistics, May 2024.
2 Totals may not sum due to rounding.


For registered pesticides, certain information must be provided in the languages of the country or countries of final destination. Table 4 presents the estimated respondent burden for multilingual product labeling of registered exported pesticide products. The labeling requirements may be met by supplemental labeling attached to either the product container or the shipping container. EPA estimates that it will take respondents approximately 5.5 hours at a cost of $397.11 to meet the multilingual labeling requirement for each product. This estimation is based on the estimate that to prepare one label in one language would take approximately one hour, and that, on average, exporters prepare a label for each of the major destinations of export shipments. This equates to a total annual burden of 8,047 hours and a total annual burden of $580,968 across all responses.
Table 4. Respondent Burden and Cost for Registered Exported Pesticide Product Translation

Collection Activity
Burden Hours
Total

Managerial
Technical
Clerical
Hours
Cost ($)

$135.50/hr 
$74.28/hr 
$51.38/hr 


Translate labels
0
5
0
5
371.42
Complete paperwork and store information
0
0
0.5
0.5
25.69
Total
0
5
0.5
5.5
$397.11
Annual Burden: 5.5 hours x 1,463 exported registered products = 8,047 hours
Annual Costs: $397.11 x 1,463 exported registered products = $580,968
1 Hourly wage rates are fully loaded wage rates based on NAICS 3250A1 – Chemical Manufacturing (3251, 3252, 3253, and 3259 only) from U.S. Dept. of Labor, Bureau of Labor Statistics, May 2024. 
2 Totals may not sum due to rounding.


13. RESPONDENT CAPITAL AND O&M COSTS:
 Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no operational and/or maintenance costs.
14. AGENCY COSTS:
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. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
14a. AGENCY ACTIVITIES AND FREQUENCY
Agency costs for this information collection consist mainly of full-time employee (FTE) time spent, the majority of which is due to recordkeeping associated with the receipt of the acknowledgment statements, review of transmissions to be sent to foreign governments, and costs associated with the transmittal of acknowledgment statements to the appropriate government official in the importing country.

14b. AGENCY BURDEN AND LABOR COST
Agency wages are shown in Table 5. The fully loaded hourly wage rates for managerial, technical, and clerical occupations for NAICS 999100 – Federal Executive Branch are $128.12, $85.53, and $47.22, respectively.

Table 5. Federal Government Labor Costs Using NAICS: 999100 Federal Executive Branch
Labor Category:
Formula
Managerial
Technical
Clerical
Unloaded Hourly Rate1
 = W
$73.56 
$49.11 
$27.11 
Benefits Percentage2
Lb = B/W
45.1%
45.1%
45.1%
Benefits per hour
B = W*Lb
$33.21 
$22.17 
$12.24 
Loaded Hourly Rate
Wb = W + B = W(1+Lb)
$106.77 
$71.28 
$39.35 
Overhead Percentage3
Lo = OH/Wb
20%
20%
20%
Overhead per hour
OH = Wb*Lo
$21.35 
$14.26 
$7.87 
Fully Loaded Hourly Rate
Wf = Wb + OH
 = W + B + OH  
$128.12 
$85.53 
$47.22 
1. Data Source: U.S. Bureau of Labor Statistics, May 2024 data, https://data.bls.gov/oes/#/industry/999100 
NAICS 999100 - Federal Executive Branch
Standard Occupational Codes:
Managerial:	11-0000, Management Occupations
Technical:	19-0000, Life, Physical, and Social Science Occupations 
Clerical:		43-0000, Office and Administrative Support Occupations 
2. Fringe benefits/wage per hour.
3. U.S. Environmental Protection Agency, EPA Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other EPA Actions, December 15, 2020, available at https://www.epa.gov/sites/default/files/2020-12/documents/epa_handbook_on_valuing_changes_in_time_use_121520_final_508.pdf. The recommended default for overhead is 20% of the loaded hourly rate inclusive of fringe benefits.

The EPA estimated hourly burden is 20 minutes (0.33 hours) per statement. Based on this estimate, annual costs are determined by multiplying hourly burden by the wage rate for technical labor (Table 6). In addition to the collection activities below, the Agency receives 30 inquiries per year and spends one hour responding to each inquiry. The burden of responding to inquires is 20% managerial, 65% technical, and 15% clerical. The inquiry responses add 30 hours to the total annual burden estimate and $2,649 to the total annual cost estimates captured in the annual totals below Table 4.

Table 6. Agency Processing Burden for FPAS Requirement
Collection Activity
Minutes
Annual Cost ($)

Technical
$85.53/hr

Receive, review acknowledgment statements for completeness, and scan to make digital copies
7
$9.98
Data entry of information in acknowledgment statements
4
$5.70
Make necessary copies and transmit submission to appropriate government officials of importing countries
3
$4.28
Review of prepared submission by OCSPP/OPS/ICRB international team, and transmission of the documentation to the appropriate government authority 
3
$4.28
Maintain a file of all submissions
3
$4.28
Total
20
$28.51
Annual Burden: (1,951 statements x 20 minutes) + 30 hours for inquiries = 680 hours 
Annual Costs: (1,951 statements x $28.51) + $2,649 for inquiries = $58,275
1Hourly wages rates are fully loaded wage rates based on NAICS code 999100 - Federal Executive Branch from U.S. Dept. of Labor, Bureau of Labor Statistics, May 2024.
2 Totals may not sum due to rounding.

14c. AGENCY NON-LABOR COSTS
There are no non-labor costs.
14d. AGENCY TOTAL COSTS
Annual Burden: (1,951 statements x 20 minutes) + 30 hours for inquiries = 680 hours 
Annual Costs: (1,951 statements x $28.51) + $2,649 for inquiries = $58,275
15. CHANGE IN BURDEN:
 Explain the reasons for any program changes or adjustments reported on the burden worksheet.
There is a decrease of 2,595 hours in the total estimated respondent burden compared with that identified in the ICR currently approved by OMB. This decrease reflects EPA's adjustment of the estimated total annual number of responses to reflect the actual number of FPAS received by the Agency in recent years (2022 to 2024). This change is an adjustment.
16. PUBLICATION OF DATA:
 For collections whose results will be published, outline the plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The Agency does not intend to publish results of this information collection.
17. DISPLAY OF OMB CONTROL NUMBER AND EXPIRATION DATE ON INSTRUMENTS:
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.
18. CERTIFICATION STATEMENT:
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.
SUPPLEMENTAL INFORMATION
PRA Burden Statement 
This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0027). Responses to this collection of information are mandatory for certain persons, as specified at 40 CFR 152.25(f). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 1-8 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the Deputy Director, Data and Enterprise Programs Division, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.
You can also provide comments to the Office of Information and Regulatory Affairs, Office of Management and Budget via https://www.reginfo.gov/public/do/PRAMain. Find this particular information collection by selecting ‘‘Currently under 30-day Review—Open for Public Comments’’ or by using the search function.
All comments received by EPA will be included in the docket without change, including any personal information provided, unless the comment includes profanity, threats, information claimed to be Confidential Business Information (CBI), or other information whose disclosure is restricted by statute. Do not submit electronically any information you consider to be CBI or other information whose disclosure is restricted by statute.
LIST OF ATTACHMENTS
The attachments listed below can also be found in the docket for this ICR. The docket for this ICR is accessible electronically through https://www.regulations.gov using Docket ID Number: EPA-HQ-OPP-2021-0749.
Attachment
Description
A
Screenshots of Salesforce MyPest Submission System and current FPAS Electronic Submission (EPA Form 9600-026)
B
Consultation Summary (Stakeholder Engagement)
REFERENCES 
7 U.S.C. 136o - Section 17 of FIFRA available at Summary of the Federal Insecticide, Fungicide, and Rodenticide Act | US EPA 
40 CFR 152 available at https://www.ecfr.gov/current/title-40/chapter-I/subchapter-E/part-152 
40 CFR 168 available at https://www.ecfr.gov/current/title-40/chapter-I/subchapter-E/part-168/subpart-D/section-168.75