On April 20, the U.S. Customs and Border Protection's (CBP) launched 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 also introduces a new layer of risk: refund submissions have the potential to trigger deeper scrutiny of past filings.
Gaia Dynamics 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 14-month period spanning December 2024 through February 2026.
And, found a 30% discrepancy rate, as outlined in its data report, The Refund Trap: Why IEEPA Recovery Can Trigger Hidden Compliance Exposure.
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.
"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," says 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."
Key takeaways:
- Nearly one in three entry summaries (30.1%) contained discrepancies for simple entries (1- or 2-line items). The error rate increases to 80% for entries with 50-plus 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-plus 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.
