"We're talking about real money for real businesses," said Tom Anderson, owner of a mid-sized manufacturing firm in Ohio that imports steel components. "We've paid over $2 million in these tariffs. If it takes the government years to refund that money—assuming we even win in court—some companies won't survive the wait."

The filing has also raised concerns about the unequal power dynamic between the government and private businesses in trade disputes. While tariffs take effect immediately and are enforced rigorously, the same efficiency apparently doesn't apply when the government must return funds.

As Americans like to say, "all politics is local"—and this issue resonates particularly strongly in swing states like Pennsylvania, Wisconsin, and Michigan, where manufacturers have been hit hardest by tariff costs. Business groups in these states have lobbied Congress to require faster refund mechanisms if courts invalidate trade restrictions.

Legal scholars noted the court filing could actually strengthen plaintiffs' arguments. "If the government admits that refunds are prohibitively difficult, that's an argument for injunctive relief—stopping the tariffs before they're collected rather than trying to get the money back later," explained Rebecca Kim, a professor of administrative law at Columbia Law School.

The broader tariff battles have divided Washington along both partisan and regional lines. While Trump administration officials argue that tariffs protect American workers and national security, critics—including some Republicans from manufacturing states—contend the levies have increased costs for businesses and consumers while yielding minimal strategic benefits.

Multiple federal judges have already ruled against specific aspects of the tariff program, finding that the administration exceeded its statutory authority under trade laws. Those cases are now on appeal, but the refund question looms large: if the tariffs are ultimately declared illegal, how will affected businesses recover their payments?

The 4 million man-hours estimate, if accurate, would represent one of the largest administrative undertakings in Customs history—larger than the entire annual workload of some federal agencies. Trade groups questioned whether the figure was inflated to discourage legal challenges or delay accountability.

For now, businesses facing tariff bills must decide whether to continue paying and hope for eventual refunds, or to challenge each transaction individually—a process that carries its own costs and complexities. The court filing suggests that either path will be lengthy and uncertain.