General Motors expects a $500 million refund for International Emergency Economic Powers Act tariffs paid in 2024, following the Supreme Court's invalidation of IEEPA duties earlier in 2025. The automaker disclosed this projection during its Q1 2025 earnings call, though CFO Paul Jacobson noted the company has not adjusted free cash flow guidance because refund disbursement timing remains undefined.
For trade compliance teams managing tariff exposure calculations, the IEEPA invalidation creates an immediate action item: companies that remitted IEEPA tariff payments in 2024 may be entitled to refunds. However, the GM case illustrates a critical distinction — IEEPA relief does not extend to Section 232 levies on steel and aluminum imports, which remain fully enforceable and constitute the bulk of GM's ongoing tariff burden.
The financial impact is substantial even with anticipated refunds. GM incurred $200 million in tariffs in Q1 2025 alone — and that figure already accounts for the expected $500 million IEEPA refund as a net adjustment. The automaker projects total tariff exposure between $2.5 billion and $3.5 billion for 2026, driven primarily by Section 232 steel and aluminum levies that remain intact.
For engineering teams maintaining duty rate databases, this divergence between invalidated IEEPA rates and active Section 232 rates demands precise classification handling. Any HTS codes previously subject to both IEEPA and Section 232 duties now require updated rate calculations reflecting only the surviving 232 levies. Stale rate caches referencing IEEPA amounts will produce incorrect landed cost projections.
GM's mitigation strategy offers a template for how importers are managing Section 232 exposure: the company hedges aluminum supply and staggers steel contracts across spot rates, one-year terms, and two-year agreements. This diversified approach smooths cost volatility but does not eliminate the underlying duty liability on imported steel and aluminum products.
The refund eligibility window and claims process for invalidated IEEPA payments has not been formally detailed by CBP. Trade compliance systems should maintain historical records of IEEPA-related payments to support refund claims once procedural guidance is issued. Meanwhile, Section 232 duty calculations on steel and aluminum imports must continue without interruption.