核心量化讯号是：在 2025 年，中国申报对美出口与美国海关记录到港之间出现创纪录的 USD 112 billion 差额，意味著最多约 25% 的中国来源货运可能未被正确纳入关税征收。市场传闻与此一致：有招揽讯息宣称中美运输价格为每公斤 USD 0.70（kg），且「含税」；一些业者声称可节省 40%-50% 成本；Kersey 估计这让对手能比他低价 10%-20%。物流高管描述的报价显示，价值 USD 1,000 的货物可用 USD 1,200 全包送达，但预期仅关税就接近 USD 1,000，这暗示存在系统性的低报价值或错误归类，且常透过 Delivered Duty Paid 架构与可快速设立、并在执法前解散的空壳进口商操作。
当局已开始回应，包括在 2025 年 8 月启动跨部门贸易诈欺专案小组、开设吹哨者管道，以及导入 AI 辅助监测；同时国会提出更严格的非居民进口商资产要求，并考虑取消「first sale」估价规则。执法仍受司法管辖限制、空壳公司快速更替与资源取舍所约束；另有报导称 DHS 将部分调查能力转向移民执法，且案件结案可能需数年。Bloomberg Economics 估算，若该差额反映逃税，自 2025 年 2 月以来约有 USD 3.5 billion 关税收入未被征得；这种不匹配也显示，相较于美国进口头条数据所暗示的情况，供应链去中国化可能进展较慢。
Bloomberg reports that a surge in suspected tariff evasion is widening the gap between US trade policy goals and real import behavior, centered on offers to move Chinese goods into the US at implausibly low all-in prices. Michael Kersey of American Lawn Mower Company says his firm paid tariffs as high as 45% over the past year, while competitors appear to bypass duties and undercut compliant sellers. The policy backdrop is unusually volatile, with President Donald Trump maintaining steep tariffs even after a Supreme Court ruling found many measures illegal, and businesses describing evasion itself as more damaging than tariffs.
The core quantitative signal is a record USD 112 billion discrepancy in 2025 between China’s reported exports to the US and US Customs’ recorded arrivals, implying up to about 25% of China-origin shipments may have avoided proper tariff capture. Market anecdotes match that pattern: solicitations advertised China-US shipping at USD 0.70 per kilogram (kg), “tax included,” and some operators claimed 40%-50% cost savings; Kersey estimates this enables rivals to price 10%-20% below him. Logistics executives described offers where USD 1,000 of goods could be delivered for USD 1,200 all-in despite expected duties near USD 1,000 alone, suggesting systematic under-valuation or misclassification, often routed through Delivered Duty Paid structures and shell importers that can be created quickly and dissolved before enforcement.
Authorities have started to respond, including an interagency trade-fraud task force launched in August 2025, a whistleblower channel, and AI-assisted monitoring, while Congress has floated tighter non-resident importer asset requirements and elimination of the “first sale” valuation rule. Enforcement remains constrained by jurisdictional limits, shell-company churn, and resource tradeoffs, with reports that DHS shifted some investigative capacity toward immigration enforcement and that case resolution can take several years. Bloomberg Economics estimated that if the gap reflects evasion, roughly USD 3.5 billion in tariff revenue went uncollected since February 2025, and the mismatch also indicates supply-chain diversification away from China may be less advanced than headline US import data suggest.