On February 23, the Commission announced a Pilot Program to test an expedited administrative process for modification and advisory opinion proceedings under Commission Rule 210.76. Modification proceedings determine whether a “carve-out” for a redesigned or new product should be added to an existing order. Under the Pilot Program, a petition for modification must state the changes desired, show that a redesigned or new product is outside the scope of an existing order, and, if the petitioner was a respondent found in violation of Section 337, demonstrate that the product could not have been adjudicated during the original investigation. The Commission may also issue advisory opinions, which are non-appealable final Commission determinations whether importation of a redesigned or new product will violate an existing exclusion, consent, or cease and desist order. Under the Pilot Program, any person may petition the Commission. For example, would-be importers could use either modification or advisory proceedings to determine whether their products would violate a general exclusion order. For modification or advisory opinions, the Commission may refer proceedings to (1) the Office of the General Counsel (for cases involving “a pure question of law”), with the Commission’s final decision normally issued within 60-90 days; (2) OUII (for cases involving “minimal fact finding”), with the Commission’s final decision issued within 90-180 days; or (3) an ALJ (for cases involving “extensive fact finding”), with the Commission’s final decision issued within 6-9 months.