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Developing a new helmet normally takes a lot longer than 15 months, so I'm sure Giro had this underway before the end of 2022 in which case they can apply for exception.
The UCI does often consult manufacturers (see recent lever debacle) but in this case I believe those rules were a bit of a kneejerk reaction to the Specialized TT5.
It's not on the exceptions list
It looks to me like they've taken the UCI box and just maxed it out completely. Having said that, those dimensions were only announced very recently so I imagine Giro had this in development before the rules were shared. So I would expect to see it added to that exceptions list very shortly.