New data shows tariff errors and discrepancies are widespread across U.S. imports as refund process opens under CBP’s new CAPE System

SAN FRANCISCO, April 21, 2026 /PRNewswire/ — Gaia Dynamics, the leading AI-powered trade compliance platform, today released its data report, The Refund Trap: Why IEEPA Recovery Can Trigger Hidden Compliance Exposure, which examines how IEEPA refunds surface both recovery and exposure, and why refund decisions now require a full view of historical data at a particularly consequential moment for importers.

This urgency is underscored by U.S. Customs and Border Protection’s (CBP) April 20, 2026 launch of the Consolidated Administration and Processing of Entries (CAPE) system, which gives importers the ability to revisit historical entries and recover duties at scale. But this same process introduces a new layer of risk: refund submissions have the potential to trigger deeper scrutiny of past filings. Before pursuing recovery, organizations must establish a clear and comprehensive understanding of their position, including recalculating duties at the line-item level and identifying both overpayments and underpayments across entries.

This risk is not theoretical. Gaia Dynamics’ report examined over 300,000 line items, representing approximately $1.04 billion in declared goods and $197 million in duties filed either manually or through a third-party platform over a fourteen-month period spanning December 2024 through February 2026. While this dataset represents a subset of total U.S. import activity, it captures a broad cross-section of industries and tariff conditions during the most volatile period in recent years.

Key findings include:

Nearly 1 in 3 entry summaries (30.1%) contained discrepancies for simple entries (one or two line items). The error rate increases to 80% for entries with 50+ line items.
Importers left significant money on the table with $35 million in recoverable overpayments and $29.4 million in underpayment exposure.
Effective tariff rates tripled from ~8% pre-April 2025 to ~25% by Q3 — driven by IEEPA reciprocal tariffs. Filers consistently lagged rate changes, first underpaying by 12+ percentage points in April, then overcorrecting by 4–5 points through year-end.
The majority of entries included IEEPA-related tariffs, which account for the overwhelming share of duties filed, signaling a fundamental shift in the tariff landscape.

Since early 2025, the tariff environment has been defined by constant change. Between February 2025 and April 2026, the Trump Administration issued more than 60 distinct tariff-related announcements, including new reciprocal tariffs, rate adjustments, enforcement directives, and legal reinterpretations under IEEPA. This rapid succession of policy changes created a moving target for importers and brokers, forcing continuous adjustments of classifications, valuations, and duty calculations. The Supreme Court’s 2026 reversal of key IEEPA authorities has only compounded the complexity, reopening past filings to review while exposing the cumulative impact of more than a year of regulatory volatility.

“Over the past 18 months, brokers and importers have been navigating constant policy shifts, and what we’re seeing in this data isn’t simply human error but rather the result of a system under sustained pressure where even highly experienced teams were forced to make judgment calls as the rules kept changing,” said Emil Stefanutti, CEO of Gaia Dynamics. “With refunds now available, a data-driven approach is essential. Platforms like Gaia Dynamics are designed to extend the capabilities of brokers and compliance teams, enabling them to evaluate entries at scale, apply tariff-specific logic, and move forward with confidence in a complex trade environment.”

To understand the full scope of refund-related risk and recovery opportunities, access The Refund Trap: Why IEEPA Recovery Can Trigger Hidden Compliance Exposure at https://www.gaiadynamics.ai/whitepapers.

About Gaia Dynamics

Gaia Dynamics is an AI-driven trade technology platform founded in 2025 in partnership with Andrew Ng’s AI Fund. Headquartered in Palo Alto, California, the company leverages cutting-edge artificial intelligence to simplify complex processes in tariff classification, regulatory compliance and supply chain optimization. Gaia Dynamics equips customs brokers, consultants and brands with the tools they need to navigate global trade with ease. To learn more, please visit: https://www.gaiadynamics.ai/.

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