SUPPORTING STATEMENT
International Mail Duty Worksheet
OMB No. 1651-0NEW
A. Justification
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.
Background
As noted in Executive Order (EO) 14195 of February 1, 2025 ("Imposing Duties To Address The Synthetic Opioid Supply Chain In The People's Republic Of China"), as amended by EO 14228 of March 3, 2025 (“Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China”), imports from China and Hong Kong play a significant role in the synthetic opioid crisis in the United States. EO 14195 was suspended enforcement on covered goods that otherwise would be eligible duty-free de minimis treatment until the Secretary of Commerce notified the President that there were adequate systems in place to collect tariff revenue on covered goods from the People’s Republic of China (PRC) that otherwise would be eligible for duty-free de minimis treatment under 19 U.S.C. § 1321(a)(2)(C) and the implementing regulations.
April 2, 2025, the President issued EO 14256 (“Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports”) that states shipments from the PRC (and Hong Kong) that are entered for consumption on or after 12:01 am eastern daylight time on May 2, 2025 are no longer eligible for duty-free de minimis treatment under 19 U.S.C. § 1321(a)(2)(C). This EO includes all shipments of articles, including international postal shipments.
All postal shipments containing goods sent to the United States through the international postal network from the PRC, including Hong Kong, and transported by carriers, that are valued at or under $800, and that would otherwise qualify for the de minimis exemption authorized in 19 U.S.C. § 1321(a)(2)(C), shall be subject to the duties described in subsections 2(b) and 2(c) of EO 14256.
EO 14256 requires all carriers that transport international postal packages from the PRC, including Hong Kong, to the United States as part of or on behalf of the international postal network to report to U.S. Customs and Border Protection (CBP) the total number of postal items containing goods and, if applicable, the value of each postal item containing goods, transported per conveyance, in the timeframe and manner prescribed by CBP. EO 14256 likewise authorizes CBP to require the postal carrier transporting the international postal package into the United States to remit payment of the duty described in subsection 2(c) to CBP monthly or on such other periodic timeframe as CBP determines appropriate. Additionally, CBP may issue regulations and guidance as necessary or appropriate to implement and enforce this requirement.
Proposed Emergency Changes
The following new information collection listed below are being submitted to OMB for consideration of approval on an emergency clearance, with the justification of an unanticipated event and reasons to believe following the normal PRA process is likely to prevent or disrupt the collection of information and cause public harm.
Introduction of the CBP International Mail Duty Worksheet:
In order for carriers to submit the information required by EO 14256, as amended, carriers will fill out the CBP International Mail Duty Worksheet (IMDW) and submit it via email to CBPDM@cbp.gov and IntlMailDutyHelp@cbp.dhs.gov.
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 by U.S. Customs and Border Protection (CBP) is necessary to allow CBP to track and collect appropriate duties for international mail shipments as required by EO 14256, as amended.
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.
The first and second page of the CBP International Mail Duty Worksheet will be submitted by email. Carriers will email the worksheet to CBPDM@cbp.gov and IntlMailDutyHelp@cbp.dhs.gov.
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.
CBP has minimized duplication as much as
possible but is constrained by statutory requirements. CBP is using
many existing processes and data elements (such as those on the
manifest) to implement EO 14256, as amended, but some additional data
is needed and that is what is collected on the worksheet. In
addition, some of the data that is needed is already collected under
the STOP Act, but by statute that data may only be used for security
purposes. As such, CBP must collect that data again to use it for
revenue and admissibility purposes.
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.
Describe consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
If the information were not collected, carriers would not be able to comply with information submission requirements in EO 14256 and CBP would not be able to track and appropriately assess duties for international mail packages in accordance with EO 14256.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
This information is collected in a manner consistent with the guidelines of EO 14256 signed on April 2, 2025.
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.
This collection is being submitted as an emergency and does not require notice for comment, CBP will solicit public comments during the next extension/revision as required by 5 CFR 1320.8(d).
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.
This information collected is covered by PIA:
DHS/CBP/PIA-003 Automated Commercial Environment (ACE), dated July 31, 2015,
And SORN :
DHS/CBP-001 Import Information System (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 associated with this collection.
Provide estimates of the hour burden of the collection of information.
Public Cost
The estimated cost to the respondents is $51,249.60. This is based on the estimated burden hours (1,440) multiplied by the average hourly wage rate for importers ($35.59). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2023 median hourly wage rate for Cargo and Freight Agents ($23.24), which CBP assumes best represents the wage for importers, by the ratio of BLS’ Q4 2023 total compensation to wages and salaries for Office and Administrative Support occupations (1.4774), the assumed occupational group for importers, to account for non-salary employee benefits.1 CBP assumes an annual growth rate of 3.64% based on the prior year's change in the implicit price deflator, published by the Bureau of Economic Analysis.2
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no record keeping, capital, start-up or maintenance costs associated with this information collection.
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 $101,073.60. This is based on the number of responses that must be reviewed (720) multiplied by the time burden to review and process each response (2 hours) = 1,440 hours multiplied by the average hourly loaded rate for other CBP Officers ($70.19)3 = $101,073.60.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14.
This information will be collected under a new information collection.
16. For collection of information whose results will be published, outline plans for tabulation, and publication.
This information collection will not be published.
17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate
CBP will display the expiration date for OMB approval of this information collection.
18. “Certification for Paperwork Reduction Act Submissions.”
CBP does not request an exception to the certification of this information collection.
No statistical methods were employed.
1 Source of median wage rate: U.S. Bureau of Labor Statistics. Occupational Employment and Wage Statistics, “May 2023 National Occupational Employment and Wage Estimates United States.” Updated April 3, 2024. Available at https://www.bls.gov/oes/2023/may/oes_nat.htm. Accessed June 4, 2024. The total compensation to wages and salaries ratio is equal to the total compensation cost per hour worked for Office and Administrative Support occupations ($33.98) divided by the wages and salaries cost per hour worked for the same occupation category ($23.00). See “Table 2. Employer Costs for Employee Compensation for civilian workers by occupational and industry group.” Bureau of Labor Statistics, “Employer Costs for Employee Compensation – December 2023.” Released March 13, 2024. Available at https://www.bls.gov/news.release/archives/ecec_03132024.pdf. Accessed June 4, 2024.
2 To adjust to 2024 dollars, multiply by the 2022-2023 percent change in the Bureau of Economic Analysis's Implicit Price Deflators for Gross Domestic Product (122.273/117.973-1). See “Table 1.1.9. Implicit Price Deflators for Gross Domestic Product,” Line 1 Gross Domestic Product, annual. Bureau of Economic Analysis. Updated May 30, 2024. Available at https://apps.bea.gov/iTable/?reqid=19&step=2&isuri=1&categories=survey#eyJhcHBpZCI6MTksInN0ZXBzIjpbMSwyLDMsM10sImRhdGEiOltbImNhdGVnb3JpZXMiLCJTdXJ2ZXkiXSxbIk5JUEFfVGFibGVfTGlzdCIsIjEzIl0sWyJGaXJzdF9ZZWFyIiwiMjAxNiJdLFsiTGFzdF9ZZWFyIiwiMjAyNCJdLFsiU2NhbGUiLCIwIl0sWyJTZXJpZXMiLCJBIl1dfQ==. Accessed June 4, 2024.
3 CBP bases this wage on the FY 2024 salary and benefits of the national average of CBP Officer Positions, which is equal to a GS-11, Step 10. Source: Email correspondence with CBP’s Office of Finance on June 17, 2024.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement |
| Author | Shade Williams;Faith Parum |
| File Modified | 0000-00-00 |
| File Created | 2025-05-19 |