Global Supply Chain Tariffs
Paul J Noble
Rates barely moved, but the rules changed completely. Gaia Dynamics founder Emil Stefanutti explains why tariff compliance has become a data problem, and why most importers are losing.
If you run a supply chain, the last 12 months probably felt like a year of whiplash. A Supreme Court ruling, a stopgap global surcharge, a refund process measured in the hundreds of billions, and a brand new tariff regime that arrived within minutes of the old one expiring. Yet for all the headlines, the average duty an importer pays today looks remarkably similar to what it paid a year ago.
The story is not the changing rates themselves, but the operating environment underneath it. More shipments under scrutiny, a regulator that has shifted from facilitation to enforcement, rules that change overnight, and a shrinking bench of professionals who know how to navigate them. For supply chain leaders, tariffs are no longer a line item; they are a permanent operating condition.
The Past 12 Months: A Year Of Legal And Operational Whiplash
The year began in the shadow of the International Emergency Economic Powers Act (IEEPA) tariffs, and the “Liberation Day” reciprocal tariffs of April 2025. On top of that, the de minimis exemption ended in August 2025, meaning millions of low-value parcels that once cleared with minimal review now required formal classification and duty payment.
On February 20, 2026, the Supreme Court ruled 6 to 3 that IEEPA does not give the president authority to impose broad tariffs, invalidating the reciprocal duties. The scale of what had been collected was staggering. CBP told the Court of International Trade that more than 330,000 importers paid roughly $166 billion in IEEPA duties across more than 53 million entries.
The administration imposed a 10% global tariff under Section 122 of the Trade Act of 1974, effective February 24 for a statutory maximum of 150 days. At the same time, the Commerce Department expanded Section 232 coverage, and the U.S. Trade Representative launched dozens of Section 301 investigations to build a more durable regime.
Refunds became their own operational saga. CBP built a new system inside ACE called CAPE to process claims in bulk. By late May, CBP reported that roughly $85 billion in anticipated refunds had been accepted for processing, but it also reversed course on finally liquidated entries, arguing it lacked authority to refund them without an importer-specific court judgment. Phase 3 of CAPE, which covers entries liquidated more than 80 days ago for importers with pending cases, is now scheduled for October 6 after an August delay.
On July 24, Section 122 expired by law and, in the same minute, new Section 301 duties of 10 to 12.5% took effect on products from 80 countries, covering roughly 99.4% of U.S. imports. Unlike its predecessor, this layer carries no expiration date. It is also already being challenged in court.
TWELVE MONTHS IN REVIEW
• August 2025: De minimis exemption ends for all countries; low-value parcels require formal entry.
• February 20, 2026: Supreme Court strikes down IEEPA tariffs in Learning Resources v. Trump.
• February 24, 2026: 10% Section 122 global surcharge takes effect for 150 days.
• March to April 2026: Section 301 investigations launched; Section 232 coverage expanded; CAPE refund Phase 1 goes live April 20.
• May 2026: Roughly $85 billion in refunds accepted; CBP reverses position on finally liquidated entries.
• July 24, 2026: Section 122 expires; Section 301 duties of 10 to 12.5% take effect with no sunset.
• October 6, 2026: CAPE Phase 3 scheduled to open for older liquidated entries.
The net result, as one trade analysis put it, is that the duty burden for many sourcing teams barely moved. What moved was everything else.
Inside The Storm: A Conversation With Emil Stefanutti
To understand what that “everything else” looks like on the ground, I recently sat down with Emil Stefanutti, founder of Gaia Dynamics, an AI platform that helps importers, customs brokers, and logistics providers classify products, calculate duties, and audit their trade data. Gaia, coming off a recently announced Seed funding round, now processes millions of HS classifications per day, and its view across millions of real customs entries offers a rare look at how importers are coping. Here are the takeaways from our conversation.
Three forces are compounding into a perfect storm
Stefanutti framed the current environment as three pressures hitting at once.
1. Volume
The termination of de minimis pushed customs scrutiny from roughly 56 million formal shipments a year to about 1.4 billion.
2. Enforcement
According to Stefanutti, CBP has shifted its posture almost entirely from trade facilitation to enforcement.
3. Complexity
Tariff changes are arriving faster and with less notice than ever before.
“You used to get months of lead time. Now a change is announced Friday at 3 p.m., and it is effective at midnight, often before the rules are even fully defined.”
-Emil Stefanutti, Founder, Gaia Dynamics
He pointed to a line he heard from CBP officials at a recent trade summit in Dallas: “Importing is a privilege.” The government has a new posture and is no longer primarily in the business of helping goods move, they are in the business of making sure every entry is right.
The talent pipeline cannot keep up
All three forces land on the same small group of people. Stefanutti noted there are only about 14,000 licensed customs brokers in the United States, and the licensing exam has historically carried a pass rate of around 12%. No meaningful pipeline of new entrants can absorb a 25-fold increase in shipments under scrutiny.
“You cannot hire your way out of this. There are not enough brokers, and the ones we have are being asked to do exponentially more with rules that change every week.”
-Emil Stefanutti
Enforcement is now powered by AI, and exposure is near total
Perhaps the most consequential shift Stefanutti described is how enforcement works. Historically, CBP relied on spot checks, which meant an importer’s exposure to an error was probabilistic. If CBP reviewed only a small percentage of entries, most mistakes never surfaced. According to Stefanutti, CBP is now using AI to review full datasets. That changes the math entirely.
“Compliance used to be a game of odds. When the regulator reviews everything, your exposure is no longer a probability. It is close to 100%.”
-Emil Stefanutti
The dirty secret is the data
This is where Gaia’s vantage point becomes striking. In auditing roughly 3 million customs entries, the company found an average error rate of 30%. For complex entries, those with 50 or more line items or involving aluminum and steel derivatives, the error rate jumped to 80%. Critically, the errors cut both ways. Some importers were underpaying and building penalty exposure. Others overpaid and left money on the table.
Gaia found that 92% of product descriptions are insufficient to classify a product accurately, which led the company to build product enrichment tools before classification even begins. A large share of Gaia’s volume today is not classifying new products at all. It is auditing data that importers have already filed.
“Everyone wants to talk about the tariff rate. But if your product data is wrong, the rate does not matter. You are either overpaying, or you are exposed.”
-Emil Stefanutti
Three questions every importer must be able to answer
Stefanutti distilled what needs to be done into three questions that every importer should be able to answer for every product, in every market:
• What do I need to know? HS codes, tariff rates, sanctions and regulations.
• What do I need to do? Documents, certifications, label changes and partner agency compliance.
• What can I improve? Tariff engineering, origin shifts and reshoring analysis.
The first two are about survival. The third is where strategy lives, and it is only possible once the first two are grounded in an accurate, verified data foundation. This is heavily supported across the entire global supply chain, not just tariffs.
ISO is set to publish ISO25500, which lays out the framework for the future of data interoperability across systems and has wide application for tariffs and dozens of other fraud, risk, procurement, and operational use cases across the end-to-end supply chain. Humans and AI agents need verified data, and this eliminates the need for the traditional data-cleansing playbook that has long underserved organizations, systems of record, and applications.
The Lens Forward: My Perspective
Looking back over the past year, I keep returning to one idea. The tariff debate has been framed as a question of rates, but the lasting change is structural. Supply chain leaders should budget as though today’s environment is permanent, because for planning purposes it is.
Three shifts stand out to me as we look ahead.
First, trade compliance is now a verified data quality discipline. I have written often about AI readiness and the importance of a scalable data foundation. Tariffs are the most expensive proof point yet. A 30% error rate is not a customs problem. It is a master data problem that surfaces at the border. When product descriptions are insufficient 92% of the time, no amount of broker expertise or AI downstream can fully compensate.
Second, the asymmetry has flipped. For decades, importers could rely on the reality that enforcement was sampled. When the regulator runs AI across full datasets and the importer runs spreadsheets, the importer loses. The companies that match the regulator’s capability, by auditing their own data continuously rather than waiting to be audited, will turn compliance from a risk into an advantage.
Third, verified data pays twice. The refund process has quietly rewarded importers who could quickly identify, document and claim what they were owed. The same data that protects you from penalties is the data that recovers overpayments and powers smarter sourcing decisions.
WHAT SUPPLY CHAIN LEADERS SHOULD DO IN THE NEXT 12 MONTHS
• Audit historical entries now. Errors cut both ways, and overpayments are recoverable.
• Lay your data foundation at the source. Verify and accept data rather than just cleaning it as a project before classification, not after a penalty.
• Closely track refund eligibility, including CAPE Phase 3 on October 6 for older liquidated entries.
• Model tariff scenarios continuously. Rules now change with hours of notice, not months.
• Augment, do not just hire. With roughly 14,000 licensed brokers nationally, AI is how existing experts scale.
• Elevate trade compliance to the executive level. It now touches cost, cash, risk, and strategy.
The past 12 months proved that tariff policy can change overnight. The next 12 will prove which organizations built the data foundation to absorb that change. In a world where importing is increasingly treated as a privilege, trusted data is how you keep it.
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