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.
The provisions of the United States-Caribbean Basin Trade Partnership Act (CBTPA) were adopted by the U.S. with the enactment of the Trade and Development Act of 2000 (PL.106-200). The objective of the CBTPA is to expand trade benefits to countries in the Caribbean Basin. For preferential duty treatment under CBTPA, importers are required to have a CBTPA Certificate of Origin (CBP Form 450) in their possession at the time of the preference claim, and to provide it to CBP upon request. CBP Form 450 collects data such as contact information for the exporter, importer, and producer, as well as information about the goods being claimed and provides instructions for its completion.
This collection of information is provided for by 19 CFR 10.234, 10.236, part 134, 10.195, and 102.21. CBP Form 450 is accessible at: https://www.cbp.gov/newsroom/publications/forms?title_1=450
This collection of information applies to the importing and trade community, who are familiar with import procedures and with CBP regulations.
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.
For preferential treatment under the CBTPA, importers are required to have a CBTPA Certificate of Origin (Form 450) in their possession at the time of the claim, and to provide it to CBP upon request. CBP uses this information to determine if an importer is entitled to preferential duty treatment under the provisions of the CBTPA.
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.
Respondents may submit this certificate electronically by scanning it and emailing it to the CBP port where the entry was filed, or they may mail it or fax it.
Usability Testing:
CBP Customer Experience (CBPX) team evaluated the form based on user experience best practices. To increase usability, as some fields are not editable in the PDF format, the form should be transformed into a web-based form. We recommend simplifying language and clearly indicating which party is responsible for each field. Additionally, adding tooltips next to field labels surfacing relevant guidance in the instructions section would improve form navigation. Lastly, clearly marking individual form fields with requested information (e.g., single field for first name, middle initial, etc.) can reduce user confusion around required data.
CBP will take these suggestions into consideration for future improvements to the form.
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.
Without collecting this information, CBP will not be able to verify and make an accurate assessment that imported goods are eligible for duty-free or reduced-duty treatment under the CBTPA Act. The consequence to the Federal program if this information were not collected would cause a loss of control over the imported merchandise, inhibiting CBP’s mission to enforce regulatory requirements, protect American people and facilitate legitimate trade and travel.
Explain any special circumstances.
There are no special circumstances. This information is collected in a manner consistent with the guidelines of 5 CFR 1320.5(d)(2).
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 published on June 13, 2025 (90 FR 25062) on which no comments were received, and on December 01, 2025 (90 FR 55154) 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 payment of 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.
PIA coverage is provided by DHS/CBP/PIA-003 Automated Commercial Environment (ACE) and subsequent PIA updates. No SORN coverage is required as the information collected in not retrieved by personal identifier.
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 people 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.
INFORMATION COLLECTION |
TOTAL ANNUAL BURDEN HOURS |
NO. OF RESPONDENTS |
NO. OF RESPONSES PER RESPONDENT |
TOTAL RESPONSES |
TIME PER RESPONSE |
CBTPA Certificate of Origin (Form 450)
|
8,584 |
15 |
286 |
4,292 |
2 hours |
Public Cost
The estimated cost to the respondents is $313,917. This is based on the estimated burden hours (8,584) multiplied by the average loaded hourly wage rate for brokers ($36.57). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2024 median hourly wage rate for Cargo and Freight Agents ($23.99), which CBP assumes best represents the wage for brokers, by the ratio of BLS’ Q4 2024 total compensation to wages and salaries for Office and Administrative Support occupations (1.4886), the assumed occupational group for brokers, to account for non-salary employee benefits.1 CBP uses an annual growth rate of 2.42% 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.
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 this information collection is $90,314. This is based on the number of responses that must be reviewed (4,292) multiplied by the time burden to review and process each response (15 minutes or 0.25 hours) = 1,073 hours multiplied by the average hourly loaded rate for a CBP Trade and Revenue employee ($84.17)3 = $90,314.
.
15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13.
There are no increases or decreases to the burden hours reported for this information collection. There is no change to the 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 for statistical purposes.
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 2024 National Occupational Employment and Wage Estimates United States.” Updated April 2, 2025. Available at https://www.bls.gov/oes/2024/may/oes_nat.htm. Accessed June 17, 2025. The total compensation to wages and salaries ratio is equal to the total compensation cost per hour worked for Office and Administrative Support occupations ($35.86) divided by the wages and salaries cost per hour worked for the same occupation category ($24.09). 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 2024.” Released March 14, 2025. Available at https://www.bls.gov/news.release/archives/ecec_03142025.pdf. Accessed June 17, 2025.
2 To adjust to 2025 dollars, multiply by the 2023-2024 percent change in the Bureau of Economic Analysis's Implicit Price Deflators for Gross Domestic Product (125.230/122.273-1). 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, 2025. Available at https://apps.bea.gov/iTable/?reqid=19&step=2&isuri=1&categories=survey#eyJhcHBpZCI6MTksInN0ZXBzIjpbMSwyLDMsM10sImRhdGEiOltbImNhdGVnb3JpZXMiLCJTdXJ2ZXkiXSxbIk5JUEFfVGFibGVfTGlzdCIsIjEzIl0sWyJGaXJzdF9ZZWFyIiwiMjAxNiJdLFsiTGFzdF9ZZWFyIiwiMjAyNCJdLFsiU2NhbGUiLCIwIl0sWyJTZXJpZXMiLCJBIl1dfQ==. Accessed June 17, 2025.
3 CBP bases this wage on the FY 2024 salary and benefits of the national average of CBP Trade and Revenue positions. Source: Email correspondence with CBP’s Office of Finance on July 15, 2025.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement |
| Author | Shade Williams |
| File Modified | 0000-00-00 |
| File Created | 2025-12-19 |