Approximately 800 Exclusion Requests filed as of today.
The filing period is of open until January 31 and nothing is lost as the exclusion if granted is retroactive back to the September 1 imposition of the duty.
ITC has been deeply engaged in mitigation strategies for clients. They range from:
1. Exclusion Requests from the China tariffs. We have submitted or are in mid-stream for almost 20 such requests and have a really streamlined protocol in place.
2. Shifting production to third countries (Dominican Republic and Vietnam for example); and
3. Valuation strategies, including First Sale for Export; and duty drawback refund applications.