The De Minimis Fallout

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Hi everyone. Welcome to the simply trade Roundup. My name’s Annick. I’ll be your host today, and I have to welcome back. Marion Rodin, for another I think this is your fourth one today, right? So Marion rodent, she’s a CEO and director of the emerchins Trade Council and longtime advocate for emergence. Did I say that right kind of to help make sense of what is next? I mean, you have an extensive background, and then you’re also practicing. Are you still practicing law? Or is that I do? I do consulting, you know, legal and non legal capacity, yes, yeah. So we’d love to have you on and I’m so grateful, because you are definitely top of the notch when it comes to this topic. I’m pretty sure people can guess by now what we’ll be talking about. It’ll be the de minimis crisis. We actually recently had a an episode with Cindy Allen. You know, she has a segment on our podcast now, and it’s the Taylor Swift segment, we call it. And she is, she did. We are never getting back together. And it’s, it’s about the minimus, which we are never going to get back to where we were with the minimus, right? It has changed so much. I mean, it’s, it’s just, it seems like people really are not sure where to even go from here. We had so much time to prepare, or I’m not sure if there was, it was a lot of time, but it’s not a lot of time to, you know, change your whole supply, change change your whole trade strategy. So I kind of want to get into, get into, into it for listeners who missed you know our last chat. Can you quickly recap why de minimis exemption mattered so much for E commerce, and what are the biggest changes now that it’s ended on August 29 I know this is a loaded question, but maybe we can start with the beginning. Well, Cindy and Allen. Allen and I have been at this a long time, and I noticed this. So I think she was still at FedEx at the time she went from, think she went from CBP to maybe DHL, then to FedEx. But I really started noticing the growth of de minimis coming out of the financial crisis with those numbers? Well, I should say the increase in E commerce coming out of the financial crisis now, de minimis and E commerce are not the same, and as Cindy astutely pointed out, e commerce is a way of doing business. De minimis was the customs device that people use for low value shipments. They overlap, but they’re not the same. But then we went through the whole World Customs Organization process of getting a frame up framework of standards, and at the same time in I think it was technically 2016 but we finally passed the trade facilitation and Trade Enforcement Act in 2015 that raised the demands from $200 up to $800 while we’re negotiating that WCO framework that took from 2015 to 2019 because all countries started seeing what they call the tsunami of packages President Obama signed to Tia in early 2016 a lot of people think that the de minimis really shipments took off as a result of statute. I’m not convinced of that. I think what a bigger driver of using de minimis came when President Trump came into office. Now it was later in his first term, but it was the section 301, tariffs, okay, and that’s when the Chinese discovered using de minimis for direct to consumer ships. Yeah. So, you know. And then what many of us didn’t expect is something like a pandemic where all the other supply chains were sort of shut down, except for the E commerce supply chain, because was direct to consumer. Right? How many people ordered groceries, ordered supplies, toilet paper you that during the pandemic, and it was the E commerce supply chain that withstood the requirements that the government had in terms of limiting people going out shopping. So all those factors sort of conspired. Now, when I was with the previous Association, I kept talking about e commerce, and people thought I was crazy. They told me to shut up. Then I just saw it growing exponentially where traditional trade was flat, and now we’re at the point which I might have mentioned on the last podcast we did together. It’s almost like that. Tail is now wagging the dog. And I was even shocked when Felicia Pulliam came out with a statistic last year at an ACI conference where 92% of all shipments coming into the United States are de minimis shipments. I didn’t realize it was that unbalanced. Okay, so that’s really the setting that we have. Yeah, that’s a, that’s a good note that you made, because I did have a question on what the scale of impact, how many packages are, what or what share of E commerce was going through the minimus? And that’s a large amount. Yes. So, so while we we have the number of how many packages are really going through de minimis. And now, following August 29 de minimis is gone. So those packages cannot come across using de minimis correct. So what do they do? They have to file an entry, either an informal or formal entry. So informal entries are for those shipments with value less than $2,500 or below, or anything over the $2,500 it’s a formal entry. Yeah, and that’s something they need resources for, right? Because before they didn’t need those resources to do that. So now they need to first of all hire someone that you know, a team that does that right? Because that’s not easy. I think that’s the key anec because what I think many people miss with regard to de minimis, Everybody focuses on the fact that it’s duty free. Yes, that’s important. But the more important issue for de minimis is that it’s just a transportation manifest upon which which is submitted to CBP, and CBP reviews it and then releases the merchandise. So there’s minimal customs paperwork, customs processes and compliance with regard to de minimis. So it’s the simplified processes that are far more valuable than just being duty free. Yeah, and, and I feel like that’s not the only problem there is, because there’s also IEEPA tariffs, which is rising for, you know, for the packages and low value imports, and now they’re not using the minimus. It’s adding on top of the tariffs that are also going to the IEEPA tariffs that are going to come onto the packages. How is that going to work? You’ve identified something very important. It would be one thing if the President and Congress don’t forget Congress, because they did put a provision in the one big, beautiful bill. It would be one thing if they got rid of de minimis, and then a lot of E sellers had to deal with regular tariffs, which the average tariff for the US, important to us is like 2.4% Yeah, yeah. But tariff, but now you’re introducing them into a very complex environment where you have multiple tariffs stacking on top of each other, and those I eat the tariffs which are fairly high. I mean, it’s just UK and somebody else that may have 10% but most countries had between 15 and 20% China has 55% India has 50% through secondary tariffs on Russian oil, but you’re then forcing them into an environment where they have very high tariffs and complexity. Now I have always maintained that customs compliance is the trade barrier for E sellers, and that’s why de minimis was so attractive, because of those simplified processes. Now you’re throwing them into a very complex and a high tariff environment, and that’s why they are scrambling trying to figure out what to do. Obviously, we’ve known this for a while, that de minimis will go away. They’ve been shipping their goods over here, right? There’s warehouses where they can keep them. The tariffs are not really on the goods yet. We’re not. The consumers are not paying the price yet, correct? Because they pre shipped. They used de minimis to its fullest potential as long as they could. Well, this is the irony. The President imposed a ban on de minimis, on China, Canada and Mexico very early on that took effect, probably around April and, you know, he revised those who went back and forth. So ironically, it’s the Chinese companies, manufacturers that were doing direct consumer shipments that had more time to figure out the logistics so But you’re right, coming from countries that didn’t have a ban on de minimis yet. E sellers were able to front load those shipments in. Into the United States in a duty free environment to have inventory already in the United States. The problem that many small or medium sized e sellers have is they have neither the cash flow nor the inventory built up into United States to withstand this new environment or ease them into it? Yeah, I do think that bonded warehouses saw a boom during the last period, because everyone was trying to get their goods across, trying to store them in the bonded warehouses, and then now selling them for the regular price, or maybe, I mean, I would probably sell it for more so I can get some cash flow and then use that to pay off the tariffs that I need to pay now. I mean, it’s a whole structure that they gonna have to go through, right? And they would. They’ve been needing to deal with this problem for a while, way before the August of 29th But absolutely, there’s a whole different problem. So one of the most immediate effect has been postal suspension more than 30 countries, I believe, now, including Japan, Australia, India, much of Europe and South Korea have stopped or restricted shipments to the US. What is the International postal community saying about that? Why is this happening? Why? Why are they stopping their postal shipments? Well, it’s even more of a mess for postal because the postal system is really not set up to handle the duties. And Secretary of Commerce, Howard and lutnet kept talking about they were going to get a gratis vendor that would handle the tariffs. I’m like, Who is he talking about? So I was very skeptical. It was only a couple years ago that the Postal Service got the C what’s called the CM, 22 slash 23 the data set that eventually became electronic, and it was sort of forced by President Trump to get the data from the Postal Service to CBP in electronic format. So postal was a mess to begin with. Now, one of things that they ended up doing, which, again, they have to ease into it, so it so it made it a little bit more complex. So what ended up happening is they didn’t have the gratis vendors until the last minute. So the first two were zonos, I shouldn’t say gratis. They you basically have to, if you’re a shipper, you have to set up an account, because the foreign, foreign postal services are not going to set up accounts for foreign shippers to pay the duties to US Customs, so you as a shipper have to set up that account with zonos and a safe package, I think were the first two. Now there’s about a dozen of them, but on the eve of August 29 there was only two companies that were considered qualified partners or qualified entities to remit customs duties to US Customs. The other thing that they did is they set up at somewhat of a complex system where it’s tiered. Now it’s basically the shipper or the transportation company that is going to be determining which rate that not rate that they use, but how they’re going to, how they’re going to, how they’re going to assess the duties, because the air carriers in a very different position than the truck carriers. Well, the other thing is, the carrier or the filing party can pay a duty equal to the effective ie paterf rates applicable to the country of origin of the product, and that shall be assessed on the value of each durable postal item, each package. Okay, so that’s a lot of money, then that have the specific duty assessed on each package containing goods entered for consumption. So for countries with an effective IEEPA tariff rate of less than 16% $80 per item. So they’ve given you a choice. You could either do the ad valorem full IEEPA rate, or if you fall into a bucket where the country of origins IEEPA rate is less than 16% just a flat $80 and then it’s tiered so countries with an effective rate, IEEPA tariff rate between 16 and 25% that’s the majority of countries. It’s $160 per item. And then third tier is countries with an effective IEEPA rate above 25% $200 per item. Now here’s the key. After six months, the carriers cannot use the specific duty rate option, okay, and then you gotta go into the full IEEPA duty rate, okay, so that’s something important for people to understand. You. That that tiered system for postal is only good for six months. Oh, wow. Okay, so they’re going through layers, and then there’s a whole and then at the end, they’re gonna get hit by the most possible tariffs. Okay, it sounds challenging for businesses to go through this. It’s just really, really complex. Even, I think for trade professionals, we have to really read the fine print to map it out to make sure that we have it correct. Yeah, and let’s kind of talk about, you know, because businesses are pivoting to different models now. I mean, they’re trying their best to kind of, how are we going to save the money? How is it going to work out best for our business? Maybe it is paying the tariffs and paying the duties and whatever. Or there’s options. Some are doing B to B to C, business to business to customer, changing E, commerce Incoterms. I, okay, so I really have no idea on this, but it’s saying mddp and DDP. I that probably says something to you, not perfect, perfect question, because there are three constituent parts of this. There’s the business model, meaning, how do you make money, and what corporate structure do you use? Yeah. Then there’s the second issue of the logistics, meaning, where do the goods originate, how they transited, and where are they housed or warehoused once they get into the United States. And the third issue is the customs methods or the customs processes that you use? Yeah, they were all separate issues, but they’re sort of like a Venn diagram, right? They they intersect. So there are some companies that are pitching this idea of B to B to C. The basic idea is that the E seller, which may be outside the United States, would set up an LLC inside the United States, an LLC and the foreign shipper would sell The goods to its related LLC and to the Import compliance. And this company would basically do an API on the shopping cart and take like, a 6% you know, as a payment. And then they would do a flash sale, transferring title to the goods at the clearance customs clearance in the United States to this company. Well, the problem is that doesn’t solve your customs Bob, that LLC will act as the importer of record. So I think these companies, and they’re using the term merchant of record and shipper of record, then may have currency within e commerce as a concept, but it has no meaning for customs compliance whatsoever. The only phrase that matters for customs compliance is who is the importer of record and also who is the party that has a financial interest in the goods with the right to make entry. So a lot of these companies think they are going to be able to save money by, let’s say, doing a related party transaction, even okay using transfer pricing from the foreign seller or manufacturer to the related all see in the United States now, I’ve set up transfer pricing agreements and stuff for multinational corporations. They are very complex. You only do this with a lot of advanced planning and transfer pricing studies, because what customs is always looking at is the relationship between the parties influence the price paid a payable for the goods. Are they arm length transactions, and so I think a lot of small businesses do not have the wherewithal to use these fairly sophisticated techniques that are typically used by multinational corporations with armies of lawyers and accountants. The other I think that goes into the pitfalls the businesses can fall into, right? That’s another question I have for you. What are the biggest compliance, you know, pitfalls and kind of advice for small businesses needing to go through this, these challenges and customs demands now, so the three basic techniques that people or companies were selling e sell us on are B to B to C, first sale and transfer pricing. And I would say to all those small. Businesses, there’s no quick and easy fix. If it sounds too good to be true, it probably is. You have to map out the transaction. And I think what is the biggest problem for most e sellers is they don’t have the profit margin to pass on the price of the tariffs to their customers. Yeah, they’re very competitive environment. So that’s a business decision that they have to make. There may be some people who will have to review what product offerings that they sell on marketplaces and what those profit margins will be. But as far as the tariff classification, tariff engineering is perfectly legal. We’ve engaged in it for a very long time, and you can do that legitimately, but you have to be careful. And the other thing I would say about tariff engineering, tariff engineering probably is not as profitable, as attractive as it used to be, because the duty rates are based on the country of origin and not on the product anymore, and did a Harmonized Tariff Schedule. So there is a real shift. I would say that if you’re still sourcing from China to a certain degree, you’re stuck, even if you’re going into India, which many companies did in anticipation they got stuck to because the secondary sanctions on India’s purchase of Russian oil that really brought their duty rate from 25% up to 50% I saw unfortunate that they were proactive and they got stuck anyway, right? And I actually sorry I have to touch on this, because I recently saw this, and we were speaking on this. We’re like, India is great option. It’s fantastic. Get out of China, go to India. And they got screwed over. Now they’re in India. Where do you go? I mean, right, right. The the President is trying to force companies back into the United States, and I think they may not understand the complexity of what it takes to make manufactured goods. It’s the whole ecosystem. We have lost the ecosystem in electronics. We’ve lost ecosystems in certain types of products. You know, it’s not just the raw materials, but it’s the skill set, and it’s the small and medium sized manufacturers that got hollowed out, and it’s going to take a long time for that to come back. So, you know, you’ve got these different devices that are being used, tariff engineering. First Sale. I know that there’s a lot of people promoted for sale. That’s not an easy, quick fix either, because you have to show that there are two distinct back to back sales, from the manufacturer to the foreign seller, and then from the foreign seller to the US importer, that these are both bonafide sales, with arm’s length pricing in both back to back sales, and that the goods were destined for export to the United States, meaning they weren’t made to go anywhere else. And so there are very strict requirements, and CBP has put it been putting out a whole bunch of rulings on first sale. Again, it’s something that needs very careful planning. You should really get a ruling ahead of time, and a lot of small easel just don’t have the luxury of the time or the technical expertise to really go through that process. So again, not a quick fix. And then you mentioned the Incoterms I’ve heard people using mdbp to denote first sale or something. Incoterms is set by the International Chamber of Commerce. So we had the last one was 2020, I guess, the selection code terms you cannot deviate from what those terms are. DDP, delivered, duty paid is just that, and you cannot modify them in any way. So, for example, if you’re using first sale, and I remember this after 911 we had just when I was practicing law, we had just done a bunch of first sale agreements, and we had switched our inco terms to fob ocean for all of these clients. And then 911 happened, no, I’m sorry. We switched them over to FCA to a dust in place, because it’s all about the risk of loss. And then 911 happened, and we had to review those agreements and switched everybody back to fob because of supply chain security. So you always have to look at who bears the risk of loss, should something happen to those goods. That’s what the Incoterms do. They confer risk of loss, they do not confer title. So again, when you go back to the constituent building blocks, the commercial business model really should confer where title is passed between the parties, whereas the second piece, which is the logistics, should really reflect where the risk of loss occurs. And then the third piece, of course, is the customs mechanisms that you’re using. So that’s what makes this really complex. For small businesses, they just don’t have either the trade expertise and the trade consultants, either in house or outside, to help them do it. And it does take time and money, which, again, they’re in short supply of as well. And you know, this is what emerging straight council was designed, not in this we didn’t anticipate this environment necessarily, but it was really designed to give some resources to E sellers. And for the past two years, we begged people tell us your stories. How do you use the minimus, you know? And nobody wanted to come forward. And now, all of a sudden, they get a real problem. There’s only so much you can do, right? There’s probably some businesses that cannot withstand such changes and customs demands on the other side, we have, you know, we have Amazon, she and Timo, that are going through these demands as well. Which they do have more capital and cash flow, I think, to withstand such changes, though it’s not easy for them either, I suppose, right. Well, you ask a very important question, which is, what degree can marketplaces deal with these regulatory issues? Yeah, so when we were back at the WCO negotiating this framework of standards, there was two, basically three models for taxation. And again, the United States is the largest country that doesn’t have a VAT. And so we, we were the outlier. So it’s not just customs duties for many countries, it’s the value added tax or the goods and services tax as well. And so there is a vendor model where you would tax the E seller or the shipper of the goods, you would tax the intermediary, let’s say the marketplace, or you would tax the customer. Okay? So most countries did not do the vendor model because custom services regulates importers, not exporters, particularly S and E exporters, right? They’re reluctant, and they don’t have the remit or the political mandate to do so, and so most countries defaulted to the intermediary model because there were not as many marketplaces as they were e sellers, and they thought it would be easy to tax the marketplaces and also issue the regulations to them so that they would implement the regulations on all the E sellers and customers. And finally, the customer model. Countries do not want to tax the consumption of their individual citizens. Now, China sort of does have that model where you have to register your tax ID number for that, and I think their limit is $3,500 a year for imported goods ordered online. But it’s very difficult for taxing authorities to chase millions of manufacturers overseas or millions of customers in their own jurisdiction to make sure the correct amount of tax being played. Now, we do have that in the United States to a certain degree on sales tax, and it’s been a mess among the states because of the Wayfair decision that happened in 2017 or 18. They’re they’re still ironing out the bugs. So that’s why the intermediary model has been the default. But even for the marketplaces, it has been difficult to implement the very various regulations, let alone taxes. So there was a statute passed by Congress requiring that E sellers have their name, address and bank account verified by the marketplace. That took over a year to implement, and even when the deadline approached, there was a scramble at the end for certain marketplaces had a very hard time completing it. What’s most devastating that happens is more often than not, a marketplace will suspend any seller store from transacting any sales. So it’s not a great solution either, but because there are fewer marketplaces, they’re easier for the governments to manage and regulate, rather than either the seller. Users or the customers? Yeah, I think only time will tell, in the sense and it’s only the beginning. I think we’ve only been here for a week, and businesses could have, you know, been proactive and changed their business model, changed their strategy, but I think it really will tell by by doing it, you know, by putting this in place and seeing if whatever they have decided to do actually will work for their business. And I think the economy has a lot to do with it as well. What are people buying? Are we buying? So it’s a it’s a whole system, rather than just the business itself. I think although we’re going into the holiday season, where most retailers, in general, particularly e sellers, realize most of their revenue. My fear is over the next 90 days, you’re gonna see many semi e sellers, you know, close their stores and what doesn’t saying in Washington, DC, if you don’t have a seat at the table, then you’re on the menu. And I think that pap would happen with these sellers, and I knew we lost politically when Kim glass of mikto got the media to buy off on the phrase de minimis was a tariff loophole. It is not a loophole. It’s been in the law since the 19 Tariff Act of 1930 you know, has it been expanded beyond what it was originally designed for? Probably, but it’s a legitimate tool provision of the tariff law. So it’s not a loophole at all. So the question then is, what is going to be the economic fallout of the de minimis? Now, one of the things that’s important to know is this provision, a bar on de minimis did get put into the one big, beautiful bill. So we do have legislation, and I thought we had breathing breathing room, because they Congress put in some penalty provisions, $5,000 for the first violation, $10,000 for the second and subsequent violations. Okay, that starts immediately, but they put a two year phase in period for barring de minimis. It was July. It’s July 1 2027, so I thought, okay, that’s fine, because then you’re in a hierarchy of law situation which trumps no pun intended, the President’s executive order or legislation. Clearly, legislation does, but it was something like Cindy Allen noted on LinkedIn that forced me to go back and look at the legislative history. And I went back and I looked at the one big, beautiful bill, and it’s section 70531, is the provision and the statute, but it’s, I think in report two, this two volume report and Congress stated in the legislative history no section of this provision should be interpreted to diminish existing authorities of the President to enforce US laws by limiting The availability of the administrative exemption under Section 321 including to protect the revenue or to prevent the unlawful importation. By repealing the statute providing the exemption in 2027 the committee is in no way modifying or undermining actions the President has already taken or may take in the future to restrict the availability of the administrative exemption prior to the repeal date. So Congress is clearly stating, we’re going to give the president flexibility here to do what he thinks is appropriate with regard to the administrative exemption. So they’ve given him wiggle room in a way that I’m not so sure is true for the IEEPA tariffs. In the litigation, there’s a lot of talks about the IEEPA tariffs too. I think the court ruled on them that they’re not that he should have not been doing that. There seems to be a lot of back and forth, and I’m not sure who has the well authority to over, overstep anyone what is very frustrating. And I attended the oral argument of the Federal Circuit because I wanted to get a feel for the questions like the court of international trade. I listened to the oral argument online, and it was fairly short. They didn’t have a huge amount of time, but the Federal Circuit was was kind of important to be there. And what frustrated me as a trade lawyer is that the single most important thing that the Court of International Trade noted the federal. Did ultimately noted, but to me, this is what is dispositive. The tariff is a statute. It is a statute, and as such, IEEPA, you’ve got to reconcile the IEEPA statute a more general statute regarding the President’s expensive powers in national security and foreign affairs versus a specific statute setting out tax rates. Now, if you look at the US Code 19, USC, section 1202, there, there’s nothing there, okay. And if you look in the notes, it says the Harmonized Tariff Schedule of the United States is not published in the code. A current version of the Harmonized Tariff Schedule is maintained and published periodically by the United States International Trade Commission and is available at their website. Okay, so that doesn’t appear physically in the books. It’s a separate book or two books now, where every product is broken down by harmonized to your schedule number, and there’s a duty rate next to it. That’s because it’s updated every five years through the World Customs Organization and Congress has to pass it as a statute. So if you think trade professionals are having a tough time now the holidays every five years, the Christmas time is audible because the International Trade Commission may get the tariff late. Have to, has to look at how many changes there are. They get the harmonized tear schedule updates in PDF, then they have to give it to CBP in Excel spreadsheet so that it can be uploaded to the ACE system. But in the meantime, Congress has to all the changes to the Harmonized Tariff Schedule from the WCO as a domestic statute. The other thing that’s important is tariffs and taxes are very specific, and throughout our history, we fought a revolution over taxes, particularly duties, customs, duties, on tea, yeah. And so that power has always been given to the Congress and must originate in the House of Representatives. It’s very specific. So the fact that IEEPA statute does not use the word tax at all or duty is significant because there are other statutes that allows the president to impose a tariff of a particular percentage for a particular action that Congress chose not to do. So is significant. So my sense is that I suspect you know you’ve got the Court of International Trade that wrote a beautiful decision. It’s a textbook decision for an international trade law class. It has everything in it. The Federal Circuit opinion is pretty good. The dissent, you know, you gotta wonder if were they at the same oral argument as I was and but now goes to the Supreme Court, and I think you have two solid lower court decisions. I’d be shocked, truly shocked, if the US Supreme Court upholds the IEEPA tariffs. Now there’s a solution to this, and I know it’s an answer that the President doesn’t want to hear. Just go back to Congress and have then either ratify the tariffs or pass a statute authorizing him to negotiate tariffs. Yeah, but you know, when you have very slim majorities in both the House and the Senate, that’s going to be very hard to do. That is something we’ll have to just make note of and maybe see in a few months. That’s probably when we’ll see the actual repercussions from from what hap what happened, aka, the de minimis going away and the IE, by tariffs. There’s so many layers to this, right? So I want to thank you for just laying out the groundwork and giving your expertise and sharing the ins and outs of what’s happening with you know, coming to the new ways that businesses are reacting, such as the B to B to C, whether that’s an option, the Incoterms, which you spoke on, which was very interesting, and I’m sure businesses will look into that as they probably thought that would be an option for them, or it’s something they could it could do, Again, tear of manipulation and whatnot. Also the first sale valuation, we’ll see. If we get a lot of, you know, we get people writing in, and they’ll be like, Wait, can I do this? Can I not? And I’m like, maybe you need to reach out to someone as a consultant. The final caution I want to give the audience is that the part. Homeland Security and the Department of Justice has started a task force on trade fraud. So in the past, you basically had CBP, their auditors and maybe Homeland Security investigators, which are the customs agents that they split off after going into the Department of Homeland Security. But now you’re gonna have about 100,000 Department of Justice lawyers looking at trade fraud, and they’re looking beyond title 19, which is has ample authority for them to go after people. But they’re also using thorough False Claims Act. So they have a broader toolkit. They’re using title 18, which is the Criminal Code of us, and they can follow those cases in US District Court, not necessarily in the US Court of international trade. And you’re going to have a lot more government lawyers looking for customs fraud. So my my final caution to all e sellers and US importers is be careful. Do not engage in fraud, because I think there’s a higher likelihood that you’re going to get caught and they’re going to nail people. Yeah, well, I hope you’re listening very closely, because we don’t want anyone to get in trouble, and I hope this episode was informational to you. And if you have any questions towards Marion, or you know towards us, or if you want a topic covered that may be relevant to you, please let us know, and we’ll look into it, and we’ll try to find someone that can speak on that. But for now, thank you so much. Marianne, again, you give the best information, and I think I mean, you deal with it on the daily basis. So there’s no better person we could have asked. And for now, I hope everyone has a gorgeous week. I hope that you enjoyed our latest one with Amy Morgan, which was great to record, and then coming up, we’ll have some great topics. So thank you again, Marion, and we will see you maybe in a few months. Thank you so much. Thank you. Bye. Bye. You.