Emergency Justification Memo

1300 Pennsylvania Avenue, NW
Washington, DC 20229

August 28, 2025

MEMORANDUM FOR:

Dominic Mancini
Deputy Administrator
Office of Information and Regulatory Affairs
U.S. Office of Management and Budget

THROUGH:

Hemant Baidwan
HEMANT S
Acting Deputy Chief Information Officer BAIDWAN
U.S. Department of Homeland Security

FROM:

Diane J. Sabatino
(A) Executive Assistant Commissioner
Office of Field Operations
U.S. Customs and Border Protection

SUBJECT:

Emergency Request under the Paperwork Reduction Act
Regarding Modified International Mail Duty Worksheet OMB No.
1651-0147

Digitally signed by
HEMANT S BAIDWAN
Date: 2025.08.28
15:30:21 -04'00'

Digitally signed by

DIANE J. DIANE J. SABATINO
2025.08.28
SABATINO Date:
09:00:24 -04'00'

This memorandum requests emergency approval, pursuant to the Paperwork Reduction Act
(PRA), from the Office of Management and Budget (OMB), Office of Information and
Regulatory Affairs (OIRA), for the U.S. Customs and Border Protection (CBP) collection of
information titled International Mail Duty Worksheet (OMB Control number 1651-0147). The
U.S. Department of Homeland Security (DHS), on behalf of CBP, is seeking a revision to
modify the collection for carriers that transport international postal packages to the United States
as part, of or on behalf, of the international postal network to provide CBP with information
necessary to implement Executive Order (EO) 14256, as amended.
To effectuate the President’s Executive Order 14324 of July 30, 2025 (Suspending Duty-Free De
Minimis Treatment For All Countries), the Secretary of Homeland Security has determined that
appropriate action is needed to ensure collection of applicable duties as well as to modify the
Harmonized Tariff Schedule of the United States (HTSUS) as set out in the Annex to this notice.
All carriers delivering shipments to the United States through the international postal network, or
other parties if qualified in lieu of such carriers, must collect and remit either the ad valorem or
the specific duty. Carriers, or such other qualified parties approved by CBP, must apply the
same duty collection methodology for all covered shipments, but may change their duty
collection methodology once a month or on such other periodic time frame as CBP determines is
appropriate, upon providing 24 hours advance notice to CBP. Carriers, or such other qualified
FOR OFFICIAL USE ONLY

Emergency Request under the Paperwork Reduction Act Regarding Modified International Mail
Duty Worksheet OMB No. 1651-0147
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parties, must remit to CBP the duties collected pursuant to sections 3(b) and 3(c) of Executive
Order 14324 on a monthly basis or on such other periodic time frame as CBP determines is
appropriate. CBP will provide separate guidance instructing carriers and other qualified parties
on how to remit payments. The specific duty will be available for carriers and other qualified
parties to select for a period of 6 months from the August 29, 2025 effective date of Executive
Order 14324. After such time, all shipments to the United States through the international postal
network must comply with the ad valorem duty.
CBP seeks to require submission of a worksheet through which carriers will submit the
information required by, and other information necessary to implement, Executive Order 14324,
as amended. The worksheet is where the carrier will declare its duty collection methodology
(i.e., ad valorem or specific duty) for the given month, package count, country of origin, value (if
applicable), and total duty amount. The second page will be utilized by the carrier to list the
specifics of imported postal items.
CBP has taken all practicable steps to consult with interested agencies and members of the public
in order to minimize the burden of the collection of information. The previously approved
information collection collected similar information in a more limited scope. During the months
that information collection has been in effect, CBP has been in constant communication with
trade members and other federal government users of the information to ascertain what
information is useful and easily obtained, and has designed this change to this information
collection using that feedback. After the completion of the emergency approval period, CBP will
undergo the usual PRA renewal process, involving federal register notices soliciting comments,
and will make any further amendments to the information collection, as needed, at that time.
Emergency Justification
1. The Collection of Information Is Needed Prior to the Expiration of the Ordinary
Statutory Time Periods under the PRA
To properly collect these duties, CBP must collect information using the International Mail Duty
Worksheet from carriers and other qualified parties that transport international postal packages to
the United States as part of or on behalf of the international postal network. These packages are
transported to the United States on an ongoing basis and cannot be halted pending completion of
the ordinary PRA review process. Emergency processing is therefore needed in order for CBP to
immediately implement the postal duties to combat the national emergency of synthetic opioids.
Although CBP already collects advance electronic data (AED) for certain inbound international
mail shipments under the 19 C.F.R. 145.74, 19 USC 1415(a)(3)(F) provides that this information
be used “exclusively for ensuring cargo safety and security, preventing smuggling, and
commercial risk assessment targeting, and shall not be used for any commercial enforcement
purposes, including for determining merchandise entry.” Thus, CBP is unable to use the AED
collected under the STOP Act to implement the postal duties imposed by Executive Order
14324, as this information is meant for revenue collection.
2. The Collection of Information Is Essential to the Mission of the Agency

Emergency Request under the Paperwork Reduction Act Regarding Modified International Mail
Duty Worksheet OMB No. 1651-0147
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CBP is responsible for the collection of duties imposed by the United States. CBP will use the
information collected on the International Mail Duty Worksheet to determine the amount of duty
that carriers owe pursuant to Executive Order 14324. CBP can also use the worksheet as a
reference when subsequently auditing carriers’ liability for duties. Without this information,
CBP would be unable to collect duties for mail shipments.
3. Public Harm Is Reasonably Likely to Result if Normal Clearance Procedures Are
Followed
IEEPA authorizes the President “to deal with any unusual and extraordinary threat, which has its
source in whole or substantial part outside the United States, to the national security, foreign
policy, or economy of the United States.” 50 U.S.C. § 1701(a). Once the President declares a
national emergency relating to such a threat, IEEPA empowers the President to “regulate . . .
importation . . . with respect to any property, subject to the jurisdiction of the United States.”
Proclamation 10886 formally declared a national emergency in order to address and abate the
synthetic opioid crisis from the PRC, Canada and Mexico to the United States. This crisis, noted
in EO 14195, is “killing approximately two hundred Americans per day, putting a severe strain
on our healthcare system, ravaging our communities, and destroying our families,” and synthetic
opioid overdose “is the leading cause of death for people aged 18 to 45 in the United States.”
Executive Order 14324 states that it is still necessary and appropriate to suspend duty-free de
minimis treatment under 19 U.S.C. 1321(a)(2)(C) in the manner and for the articles described
below to deal with the unusual and extraordinary threats, which have their source in whole or
substantial part outside the United States, to the national security, foreign policy, and economy
of the United States. Following normal PRA clearance procedures would prevent CBP from
getting PRA authorization for the International Mail Duty Worksheet urgently needed to
properly gather all the necessary information, crucial to deal with the unusual and extraordinary
threats which have their source in whole or substantial part outside the United States.
4. Conclusion
Following the normal clearance procedures under the PRA would prevent the swift
implementation of Executive Order 14324, as amended, via the modified International Mail Duty
worksheet and would thereby constrain CBP’s ability to collect information needed to enforce
the duties imposed under Executive Order 14324.
As discussed, CBP certifies that this request meets the requirements of 5 C.F.R. § 1320.13(a) and
it is vital that this revised collection be implemented immediately. Thank you for your
consideration.
Upon approval and after implementation of this collection, CBP will undergo the normal PRA
process, including providing the opportunity for public comment, to renew the collection authority
within six months or will discontinue the collection of this information.
Please contact C. Shane Campbell, Acting Executive Director, Cargo and Conveyance Security,
at 202-818-9636 with any additional questions or concerns.