The GAO report estimates importers might owe about $32 million in duties because of invalid use of Section 232 exclusions as of Nov. 10, 2021. The analysis showed that during the period of review, importers properly utilized 61,243 exclusions to avoid paying Section 232 duties. However, there were 3,959 instances of invalid use related to certain exclusion criteria, such as a wrong exclusion identification number, the wrong country of origin, or the wrong product quantity. Of those 3,959 instances of incorrect use, 3,884, or 98%, were related to quantity.

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