The last point on that is this. For the importers of record, when making that decision whether to participate in the EDC program or to wait for Customs to refund their money directly, the special charge is identified, as was the remittance of the 18% under the special charge, if they participated in the EDC program. That was made clear to importers of record up front, so as to allow them to make their decisions.
On October 24th, 2006. See this statement in context.