GM · CIK 1467858
What General Motors Company told the SEC could break it.
Trade policy is the heaviest item in GM's register: U.S. and other import tariffs on vehicles, parts and raw materials cut its 2025 EBIT-adjusted by $3.1 billion, and it estimates a $3.0-4.0 billion hit for 2026, with the USMCA review adding uncertainty. That collides with supplier concentration — in some cases it buys systems and parts from a single source, and its two largest suppliers were about 12% of total purchases — so a disruption there could halt production. Regulation cuts the other way too: shifting ZEV mandates (California's ACC II and ACT, whose EPA waivers Congress invalidated in June 2025, now in litigation) create planning uncertainty across its EV and combustion lineup, while processing of EV battery raw materials remains concentrated in China and exposed to tariffs and export limits.
4 self-disclosed vulnerabilities, pulled from its own filings — each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Regulatory & policy
- tariffs — $3.1B EBIT-adjusted hit in 2025, estimated $3.0-4.0B in 2026; USMCA review; vehicle/parts/raw-material tariffshigh
U.S. and other governments' import tariffs on vehicles, parts, raw materials and inputs (and the ongoing USMCA review) reduced GM's 2025 EBIT-adjusted by $3.1 billion, with an estimated $3.0-4.0 billion hit for 2026; further measures may be under consideration and could materially affect results.
“In 2025, impacts to earnings before interest and taxes (EBIT)-adjusted from tariffs were $3.1 billion. Based on the current tariff environment, we estimate that impacts to EBIT-adjusted could range from $3.0 billion to $4.0 billion for the year ending December 31, 2026.”
- ZEV mandates — CARB ACC II / ACT (100% ZEV targets) and EPA waivers invalidated by Congress June 2025 (litigation ongoing)medium
GM faces shifting ZEV regulation: California's ACC II (rising light-duty ZEV percentages to 100% by 2035, adopted by many states) and ACT (heavy-duty, 100% ZEV by 2036) required EPA waivers, which the U.S. Congress invalidated via resolutions of disapproval in June 2025 — now challenged in ongoing litigation — creating planning uncertainty across its EV/ICE portfolio.
“In June 2025, the U.S. Congress passed resolutions of disapproval invalidating EPA's waivers for ACC II and ACT. These resolutions have been challenged through litigation, which is ongoing.”
SEC filing →As of 2026
Sole-source dependency
- single-source systems/components/parts; two largest suppliers ~12% of total purchaseshigh
GM in some instances purchases systems, components, parts and supplies from a single source (increasing supply-disruption risk), and its combined purchases from its two largest suppliers were ~12% of total purchases in 2025 (~11% in 2024/2023); inability of these sources to deliver could materially harm production.
“In some instances, we purchase systems, components, parts, and supplies from a single source, which may increase risk to supply disruptions... Combined purchases from our two largest suppliers overall were approximately 12% of our total purchases in the year ended December 31, 2025”
SEC filing →As of 2026
Commodity & input dependence
- EV battery raw-material processing concentrated in China (import/export/tariff risk); steel/copper/aluminum/palladium/lithium/nickellow
Processing and extraction of certain EV battery raw materials is currently concentrated in China and may be subject to import/export restrictions and/or tariffs; GM hedges a portion of forecasted commodity purchases of steel, copper, aluminum, palladium, lithium and nickel (a 10% adverse price move = ~$0.2B fair-value change), and is building a more resilient North America-focused supply chain.
“Processing and extraction of certain EV battery raw materials is currently concentrated in China and may be subject to import or export restrictions, and/or tariffs.”
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings — including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its customers
Berkshire Hathaway Inc. (Berkshire Hathaway Automotive)
“BHA maintains franchise agreements with 26 different vehicle manufacturers, although it derives a significant portion of its revenue from the Toyota/Lexus, General Motors, Ford/Lincoln, Nissan/Infiniti and Honda/Acura brands. These manufacturers normally represent approximately 90% of the revenue generated by BHA's dealerships.”
Cited →“We currently purchase engines from General Motors LLC, or General Motors, that we then prepare for marine use for certain Malibu, Axis and Cobalt boats. Our agreement with General Motors will continue through model year 2026.”
Cited →“The core brands of new vehicles that we sell, representing approximately 89% of the new vehicles that we sold in 2025, are manufactured by Toyota (including Lexus), Honda, Ford, General Motors, BMW, Mercedes-Benz, Stellantis, and Volkswagen (including Audi and Porsche).”
Cited →
Its suppliers
AMERICAN AXLE & MANUFACTURING HOLDINGS INC
“Sales to General Motors Company (GM) were approximately 39 % of our consolidated net sales in 2023, 40 % in 2022, and 37 % in 2021.”
Cited →“The Company's worldwide net sales to General Motors Company during the years ended December 31, 2025, 2024, and 2023 were 18%, 17% , and 16%, respectively.”
Cited →“The Company is highly dependent on Ford Motor Company and General Motors.”
Cited →“Customer: Ford 27 % 27 % 25 % General Motors 19”
Cited →“OEMs) worldwide, including BMW, Mercedes-Benz, the Volkswagen Group (Volkswagen, Audi, Porsche, and other brands), Stellantis, Renault, Toyota, Ford, General Motors, BYD, Great Wall Motor, and NIO.”
Cited →LG Energy Solution
“Our EV portfolio takes advantage of integrated supply chain development, including battery cell production from Ultium Cells Holdings LLC (a joint venture with LG Energy Solution) in plants in Warren, Ohio and Spring Hill,[ Tennessee]”
Cited →Universal Logistics Holdings, Inc.
“In 2025, 2024 and 2023, General Motors accounted for approximately 25 %, 18 % and 20 % of our total operating revenues, respectively, and Ford accounted for approximately 6 %, 17 % and 6 %, respectively.”
Cited →“In 2025, General Motors, one of the largest automotive and light truck manufacturers in the world, accounted for 22% of our net sales.”
Cited →“General Motors Company accounted for approximately 14 %, 12 % and 12 % of our revenues in 2025, 2024 and 2023, respectively.”
Cited →“In fiscal 2025, our three largest customers, General Motors Company, Ford Motor Company and Stellantis, accounted for 29%, 23% and 12%, respectively, of our annual sales, compared to 30%, 21% and 14%, respectively, in fiscal 2024.”
Cited →“The Company's worldwide net sales to General Motors Company during the years ended December 31, 2024, 2023, and 2022 were 17%, 16% , and 12%, respectively.”
Cited →“GM and Distribution International, Inc. (Distribution) represented 41% and 14%, respectively, of our total revenue and were our only customers representing 10% or more of our revenue for that period.”
Cited →
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