Gaia Dynamics, a customs compliance audit firm, released its report The Refund Trap: Why IEEPA Recovery Can Trigger Hidden Compliance Exposure on April 21, 2026, distributed via PR Newswire. The firm claims to have identified a 30% discrepancy rate in entries processed before CBP, rising to 80% in shipments with 50 or more line items. The study estimates USD 35 million in recoverable duties for importers who may have overpaid or misclassified entries. These figures are drawn exclusively from the company's own audited portfolio and have not been validated by CBP or any independent body. They should not be attributed to the regulator.
On April 20, 2026, CBP activated the first phase of the CAPE system, an electronic mechanism exclusively designed to process refunds for duties paid under IEEPA. This follows the U.S. Supreme Court's February 2026 ruling that struck down those tariffs, as well as subsequent orders from the Court of International Trade (CIT) directing CBP to issue refunds.
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