Equipment catalogue

What Qing knows how to buy — and what it will refuse to

categories
1478
freely routable
1283
no export gate on the item itself
classify before outreach
141
control depends on measured parameters
never routed
42
advanced-computing ECCNs

42 categories are refused at the catalogue, not escalated

A PRC-incorporated entity cannot lawfully be the seller of an advanced-computing item (ECCN 3A090 / 4A090) to any destination worldwide, non-US manufacture does not escape the Foreign Direct Product Rule, and every credible PRC accelerator vendor is Entity Listed. Qing refuses at the catalogue rather than opening a conversation and escalating, because the conversation itself creates a record. See the compliance perimeter →

12 near-duplicate pairs need curating — they are why a matched requirement sometimes comes back ambiguous

The importer collapses pure reorderings and empty qualifiers automatically. It will not decide whether “(x86)” distinguishes a product — that depends on whether an ARM variant exists, and guessing wrong destroys a real distinction. These are left for a human.

  • 1.001U dual-socket rack server (x86)↔2U dual-socket rack server (x86)
  • 1.001U tool-less ball-bearing slide rail kit↔2U tool-less ball-bearing slide rail kit
  • 1.00Active optical cable (AOC), 400G/800G↔Active optical cable (AOC), 400G/800G, 3-30 m
  • 1.00Cable management arm (CMA) 1U/2U↔Cable management arm (CMA)
  • 1.00Enterprise NVMe SSD, U.2/E1.S/E3.S, 3.84-30.72 TB↔Enterprise NVMe SSD, E3.S
  • 1.00Enterprise NVMe SSD, U.2/U.3↔Enterprise NVMe SSD, U.2/E1.S/E3.S, 3.84-30.72 TB
  • 1.00Enterprise NVMe SSD, U.2/U.3↔Enterprise NVMe SSD, E3.S
  • 1.00General-purpose 2U dual-socket rack server↔1U dual-socket rack server
  • 1.00High-capacity QLC NVMe SSD↔E1.L NVMe QLC high-capacity SSD
  • 1.00Type 2 surge protective device↔Surge protective device, Type 1+2 and Type 2
  • 0.88Rear-door heat exchanger, active (fan-assisted)↔Rear-door heat exchanger, active (fan-assisted), 60-100 kW
  • 0.88Single-phase immersion dielectric fluid, synthetic ester base↔Single-phase immersion dielectric fluid (synthetic hydrocarbon / ester)
All 1478Cooling 296Power 270IT hardware 240Facility systems 212White space 198Optics & cabling 111Compute 72Consumables 49Prefabricated 30

Compute

Each carries the questions that make two quotes comparable, and the traps specific to it

showing 60
  • 4U GPU server chassis/system (8x dual-width)4U GPU服务器
    ComputeHS 8471.50per unitCN supply: strong
    unrestricted
    7 ways buyers get burned here
    • 'OEM' means the opposite of what you think. A Chinese seller saying OEM almost always means 代工/贴牌 — they will build or relabel to your spec, with no brand IP behind it. A Western buyer hears 'made by Dell/HPE'. Never accept the word; ask which factory designed the board and which built it, and get FCC ID / CMIIT ID and PCB silkscreen photos.
    • Engineering samples sold as production silicon. ES/QS CPUs are typically 30-50% below retail, carry no vendor warranty, and can be unstable in specific workloads. Intel states the S-spec is printed only on the IHS, that 'Intel Confidential' or a missing brand string identifies an ES, and that it may retain or destroy re-marked product. QS is nearer retail but is still a sample. Demand IHS photos and an ES/QS exclusion clause with lot-level return.
    • 拆机件 sold as new. Decommissioned DDR4 RDIMMs, RAID cards and drives are a huge, largely legitimate market — the fraud is the relabelling. Refurbishers are documented as resurfacing bad sectors, zeroing power-on hours and swapping model labels. Require original sealed packaging, single-lot date codes, and per-unit health logs.
    • SMART is not proof of a new drive. Commercial tools reset SMART attributes to factory defaults in one click. On Seagate drives the FARM log is a second, harder-to-scrub record: FARM hours exceeding SMART hours indicates tampering. On SSDs, firmware can misreport capacity and health outright, so a clean SMART page means very little.
    • Altered labels defeat verification portals. Scammers copy serials from newer drives onto old units and reprint QR codes so that vendor verification appears to pass. Verify serials yourself at the OEM portal (verify.seagate.com, cway.cisco.com/sncheck, Intel's FPO/ATPO lookup), and cross-check that the serial's warranty start date is consistent with a genuinely new unit.
    • Remarked memory. A DDR5-4800 module relabelled as 6400, or SK hynix dies under a Samsung label, is caught only by comparing three layers: printed module label, SPD dump, and the die markings on the chips themselves. Any disagreement across those three is disqualifying.
    • Vendor-locked parts that boot nowhere. AMD PSB-locked EPYCs, crossflashed RAID cards and OEM-keyed drives are common in pulled stock and are functionally worthless outside their original platform. Ask about lock status explicitly; a seller who does not understand the question is a reseller, not a builder.
  • 800G ACC / AEC active electrical cable800G ACC/AEC 有源电缆
    ComputeHS 8544.42per cableCN supply: strong
    unrestricted
    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • 800G OSFP passive DAC copper cable800G OSFP 高速铜缆 (DAC)
    ComputeHS 8544.42per cableCN supply: dominant
    unrestricted
    10 questions ready6 of them decide comparabilitysee the question set →
    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • 8-GPU AI server chassis, no accelerators fitted8卡AI服务器整机（不含加速卡）
    ComputeHS 8473.30per chassisCN supply: dominant
    classify first

    THE SHARPEST LINE IN THIS CATALOGUE. Without accelerators fitted it is not 4A090. But shipping the chassis to a buyer who will fit controlled GPUs is a classic KYC red flag (Supp.3 Part 732 flags 2, 12, 13) and can be a 736.2(b)(10) or 744.23 problem. PLATFORM: allow only with a signed end-use statement naming the accelerator to be fitted, plus screening of that accelerator's classification.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Alibaba T-Head Hanguang 800 NPU平头哥 含光800
    ComputeHS 8473.30per cardCN supply: moderate
    classify first

    Control status not established, and this item class can be swept into control by the .z paragraphs because of the IC inside it. Classify before routing.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • AMD Instinct MI300X 192GB OAMAMD Instinct MI300X 192GB
    ComputeHS 8473.30per OAM moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • AMD Instinct MI308X (China-market variant)AMD Instinct MI308X 中国版
    ComputeHS 8473.30per OAM moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • AMD Instinct MI325X 256GB OAMAMD Instinct MI325X 256GB
    ComputeHS 8473.30per OAM moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • AMD Instinct MI355X OAMAMD Instinct MI355X
    ComputeHS 8473.30per OAM moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Baidu Kunlunxin P800 AI accelerator昆仑芯 P800
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Control status not established, and this item class can be swept into control by the .z paragraphs because of the IC inside it. Classify before routing.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Bare HGX/UBB baseboard, no accelerators and no NVSwitch fitted空载 UBB 基板（未装加速卡与交换芯片）
    ComputeHS 8534.00per baseboardCN supply: strong
    classify first

    Distinct catalogue SKU, not a footnote on the populated UBB. With no 3A090-class IC it is not 4A090 and typically EAR99. It is nevertheless the single most common structuring attempt for a blocked transaction. Requires red-flag 2 and 13 checks plus a named end-accelerator declaration.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Biren BR 106M / 106B accelerator壁仞 壁砺 106M / 106B
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Biren BR 166C inference acceleration card壁仞 壁砺 166C 推理加速卡
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Biren BR 166L OAM module (liquid-cooled)壁仞 壁砺 166L OAM 模组（液冷）
    ComputeHS 8473.30per OAM moduleCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Biren BR 166M OAM module (air-cooled)壁仞 壁砺 166M OAM 模组（风冷）
    ComputeHS 8473.30per OAM moduleCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Cambricon MLU370-X8 accelerator card寒武纪 思元370-X8 智能加速卡
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Cambricon MLU590 (Siyuan 590) training accelerator寒武纪 思元590
    ComputeHS 8473.30per moduleCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • ECCN 4E091 AI model weights受控人工智能模型权重
    Computeper model artefactCN supply: not made in China
    classify first

    Export status depends on what is installed. The bare chassis is broadly exportable; populated with US-origin accelerators it is caught by 3A090/4A090 and is not re-exportable from China. Classify the actual configuration, and treat a buyer who intends to fit controlled parts as a KYC red flag (Supp. 3 to Part 732).

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Enflame Yunsui S60 / L600 accelerator燧原科技 云燧 S60 / L600
    ComputeHS 8473.30per cardCN supply: dominant
    classify first

    Shanghai Enflame Technology (上海燧原科技). Site fetch failed in this pass — VERIFY product names and Entity List status before listing. FDPR analysis under 734.9(h) applies regardless. PLATFORM: block pending verification.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • HBM3 / HBM3E stackHBM3/HBM3E 高带宽存储堆栈
    ComputeHS 8542.32per stack / on-packageCN supply: moderate
    unrestricted
    7 ways buyers get burned here
    • ES/QS samples sold as retail 散片. Intel states engineering samples remain Intel property, are supplied under NDA or special loan terms, and are not for sale or resale. Identification: no brand string or base-frequency marking on the IHS, an 'Intel Confidential' label, or a four/five-digit Q-spec where a production part carries a five-digit S-spec. ES 不显 parts show 0000 in CPU-Z; ES 正显 and QS parts display correct strings and are the ones that actually fool buyers. QS is stepping-identical to retail and often perfectly stable — which is exactly why it is sold as retail. Neither carries warranty and neither can support an enterprise RMA obligation.
    • AMD Platform Secure Boot vendor lock. When PSB is enabled on an OEM platform, one-time fuses permanently bind the CPU to that vendor's BIOS signing key. A Dell-locked EPYC will not POST on a Supermicro or Gigabyte board, and the fusing is irreversible. A large share of cheap EPYC 7003/9004 secondary stock is locked, and the seller frequently does not know or does not say. Make it an explicit RFQ field and demand video proof of POST on a generic board.
    • Tray processors quoted with implied manufacturer warranty. Intel warrants boxed processors (typically three years, some one year); tray processors sold by resellers or system builders carry no Intel warranty at all — the only warranty is the reseller's. Chinese quotes for 散片 routinely say '原厂保三年' when the part is tray. Ask who honours the warranty by name.
    • 拆机 pulls sold as new. Decommissioned hyperscaler and enterprise fleets feed an enormous pull market in both CPUs and DIMMs. The parts are often genuine and often fine — the fraud is grade misrepresentation. Tells: contact-pad wear or discoloration on the CPU underside, cured thermal compound residue, missing carrier clips, loose ESD bagging instead of manufacturer trays, and wide manufacture-date spread across a single lot.
    • Label-vs-SPD mismatch on DDR5 modules. Counterfeiters batch-print thousands of identical labels with the same serial number but cannot rewrite the serial stored in each module's SPD hub. If the software-read serial differs from the printed one, the module is counterfeit. CRC errors, 'Generic' or 'Unknown' manufacturer fields, or SPD parameters that contradict the claimed speed bin all indicate crude SPD tampering.
    • Ground-off and remarked DRAM dies. A common construction is server-decommissioned downgraded chips or cheap clone dies with original markings ground away and a counterfeit vendor label applied. Defence: photograph the FBGA marking on the DRAM packages and run it through Micron's official FBGA decoder or SK hynix's part-number decoder, then confirm the resulting die matches the claimed module MPN and speed bin.
    • '128GB DDR5 RDIMM' hiding two different products. The same capacity is built either as 2Rx4 on 32Gb monolithic dies or as 4Rx4 TSV 3DS. They differ in price, achievable speed, channel loading and platform support. A quote that states only capacity and speed is not comparable to another quote of the same nominal spec.
  • Huawei Ascend 310P inference module / Atlas 300I Duo card华为昇腾 310P / Atlas 300I Duo 推理卡
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Huawei Ascend 910B AI processor华为昇腾 910B
    ComputeHS 8542.31per moduleCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Huawei Ascend 910C AI processor华为昇腾 910C
    ComputeHS 8542.31per moduleCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Huawei Atlas 800I A2 inference server华为 Atlas 800I A2 推理服务器
    ComputeHS 8471.50per unitCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Huawei Atlas 800T A2 training server华为 Atlas 800T A2 训练服务器
    ComputeHS 8471.50per unitCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Huawei Atlas 900 A3 SuperPoD / CloudMatrix 384华为 Atlas 900 A3 超节点 / CloudMatrix 384
    ComputeHS 8471.50per podCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Also engages 744.23 supercomputer end-use controls. PLATFORM: hard block.
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
  • Hygon C86 server CPU海光 C86 系列服务器 CPU
    ComputeHS 8542.31per CPUCN supply: strong
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    31 questions ready24 of them decide comparabilitysee the question set →
    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Hygon DCU Shensuan series accelerator海光 深算 DCU 加速卡
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Hygon and Higon appear in Supplement No. 4 to Part 744 (aliases include 'Chengdu Haiguang Jincheng Dianlu Sheji' and 'Higon Information Technology'). Product lines CPU 海光 / DCU 深算 confirmed on hygon.cn. PLATFORM: hard block.
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
  • Iluvatar CoreX Tiangai 100 / 150 / 300 training GPGPU天数智芯 天垓 100 / 150 / 300 训练加速卡
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Whole vendor missing from the report. Shanghai Iluvatar CoreX Semiconductor (上海天数智芯半导体股份有限公司), product line verified on iluvatar.com. NOT found on the Entity List. Still requires a §734.9(h) Advanced Computing FDPR analysis and a documented TPP/density calculation — absence from the Entity List is not a clearance.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Iluvatar CoreX Tongyang TY1000 / TY1100 / TY1200 edge module天数智芯 彤央 TY1000 / TY1100 / TY1200 边缘计算模组
    ComputeHS 8473.30per moduleCN supply: strong
    classify first

    Verified on iluvatar.com. Edge tier, most likely below 3A090 thresholds, but still needs a documented calculation.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Iluvatar CoreX Zhikai 100 inference accelerator天数智芯 智铠 100 推理加速卡
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Verified on iluvatar.com. Not Entity Listed. FDPR and TPP analysis still required.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Intel Gaudi 3 OAM / HL-325L英特尔 Gaudi 3 加速卡
    ComputeHS 8473.30per OAM moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Intel Xeon CPU Max series (Sapphire Rapids with on-package HBM2e)英特尔至强 CPU Max 系列（板载HBM2e）
    ComputeHS 8542.31per pcCN supply: moderate
    unrestricted
    7 ways buyers get burned here
    • ES/QS samples sold as retail 散片. Intel states engineering samples remain Intel property, are supplied under NDA or special loan terms, and are not for sale or resale. Identification: no brand string or base-frequency marking on the IHS, an 'Intel Confidential' label, or a four/five-digit Q-spec where a production part carries a five-digit S-spec. ES 不显 parts show 0000 in CPU-Z; ES 正显 and QS parts display correct strings and are the ones that actually fool buyers. QS is stepping-identical to retail and often perfectly stable — which is exactly why it is sold as retail. Neither carries warranty and neither can support an enterprise RMA obligation.
    • AMD Platform Secure Boot vendor lock. When PSB is enabled on an OEM platform, one-time fuses permanently bind the CPU to that vendor's BIOS signing key. A Dell-locked EPYC will not POST on a Supermicro or Gigabyte board, and the fusing is irreversible. A large share of cheap EPYC 7003/9004 secondary stock is locked, and the seller frequently does not know or does not say. Make it an explicit RFQ field and demand video proof of POST on a generic board.
    • Tray processors quoted with implied manufacturer warranty. Intel warrants boxed processors (typically three years, some one year); tray processors sold by resellers or system builders carry no Intel warranty at all — the only warranty is the reseller's. Chinese quotes for 散片 routinely say '原厂保三年' when the part is tray. Ask who honours the warranty by name.
    • 拆机 pulls sold as new. Decommissioned hyperscaler and enterprise fleets feed an enormous pull market in both CPUs and DIMMs. The parts are often genuine and often fine — the fraud is grade misrepresentation. Tells: contact-pad wear or discoloration on the CPU underside, cured thermal compound residue, missing carrier clips, loose ESD bagging instead of manufacturer trays, and wide manufacture-date spread across a single lot.
    • Label-vs-SPD mismatch on DDR5 modules. Counterfeiters batch-print thousands of identical labels with the same serial number but cannot rewrite the serial stored in each module's SPD hub. If the software-read serial differs from the printed one, the module is counterfeit. CRC errors, 'Generic' or 'Unknown' manufacturer fields, or SPD parameters that contradict the claimed speed bin all indicate crude SPD tampering.
    • Ground-off and remarked DRAM dies. A common construction is server-decommissioned downgraded chips or cheap clone dies with original markings ground away and a counterfeit vendor label applied. Defence: photograph the FBGA marking on the DRAM packages and run it through Micron's official FBGA decoder or SK hynix's part-number decoder, then confirm the resulting die matches the claimed module MPN and speed bin.
    • '128GB DDR5 RDIMM' hiding two different products. The same capacity is built either as 2Rx4 on 32Gb monolithic dies or as 4Rx4 TSV 3DS. They differ in price, achievable speed, channel loading and platform support. A quote that states only capacity and speed is not comparable to another quote of the same nominal spec.
  • Loongson 3C6000 server CPU龙芯 3C6000 服务器处理器
    ComputeHS 8542.31per CPUCN supply: strong
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • MetaX C500 / C550 / C500X / C588 / C600 training GPGPU沐曦 曦云 C500 / C550 / C500X / C588 / C600
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Replaces the report's single unverified C500 entry. Vendor listed at 688802; product line verified on metax-tech.com. Not found on the Entity List under 'MetaX' — re-screen under 沐曦/Muxi. The C600's 'domestic advanced process' claim is exactly the fact pattern §734.9(h) and §744.23 are aimed at.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • MetaX N100 / N260 / N300 inference GPGPU沐曦 N100 / N260 / N300 推理加速卡
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Verified on metax-tech.com. Not Entity Listed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • MetaX Xiyun C500 GPGPU沐曦 曦云 C500
    ComputeHS 8473.30per cardCN supply: strong
    classify first

    Control status not established, and this item class can be swept into control by the .z paragraphs because of the IC inside it. Classify before routing.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Moore Threads MTT KUAE cluster / SGX5000 AI server摩尔线程 夸娥 (KUAE) 智算集群 / MTT SGX5000
    ComputeHS 8471.50per clusterCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Confirmed on mthreads.com. PLATFORM: hard block.
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
  • Moore Threads MTT S4000 acceleration card摩尔线程 MTT S4000 大模型加速卡
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • Moore Threads MTT S5000 training/inference GPU摩尔线程 MTT S5000
    ComputeHS 8473.30per cardCN supply: dominant
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • MPO-16 / MPO-12 fibre trunk cableMPO-16 / MPO-12 光纤主干跳线
    ComputeHS 8544.70per cableCN supply: dominant
    unrestricted
    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA A100 80GB SXM4 (legacy)英伟达 A100 80GB
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA A800 40GB/80GB SXM (legacy China SKU)英伟达 A800 中国特供版
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Missing from the report. Caught by the October 2023 threshold revision. Large PRC grey-market inventory; any offer is a diversion signal. PLATFORM: hard block, and log the offering supplier.
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
  • NVIDIA B200 SXM 180GB HBM3e (Blackwell)英伟达 B200 180GB
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA B300 / Blackwell Ultra SXM module英伟达 B300 (Blackwell Ultra)
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA B30A / Blackwell China SKU (reported)英伟达 B30A 中国版 (传闻)
    ComputeHS 8473.30per moduleCN supply: not made in China
    classify first

    Control status not established, and this item class can be swept into control by the .z paragraphs because of the IC inside it. Classify before routing.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA GB200 Grace-Blackwell Superchip英伟达 GB200 超级芯片
    ComputeHS 8473.30per superchip boardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA GB200 NVL72 rack-scale system英伟达 GB200 NVL72 整机柜
    ComputeHS 8471.50per rackCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA GB300 NVL72 rack-scale system英伟达 GB300 NVL72 整机柜
    ComputeHS 8471.50per rackCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H100 NVL 94GB accelerator card英伟达 H100 NVL 94GB
    ComputeHS 8473.30per cardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H100 PCIe 80GB accelerator card英伟达 H100 PCIe 80GB 加速卡
    ComputeHS 8473.30per cardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H100 SXM5 80GB HBM3 accelerator module英伟达 H100 SXM5 80GB 加速卡
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H200 NVL PCIe 141GB英伟达 H200 NVL
    ComputeHS 8473.30per cardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H200 SXM 141GB HBM3e accelerator module英伟达 H200 SXM 141GB
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H20 96GB (China-market variant)英伟达 H20 96GB 中国特供版
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA H800 SXM 80GB (legacy China SKU)英伟达 H800 中国特供版
    ComputeHS 8473.30per moduleCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Missing from the report. Caught since October 2023. PLATFORM: hard block; treat any listing as a KYC event.
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
  • NVIDIA HGX B200 8-GPU baseboard (UBB)英伟达 HGX B200 8卡基板
    ComputeHS 8473.30per baseboardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA HGX H200 8-GPU baseboard (UBB)英伟达 HGX H200 8卡基板
    ComputeHS 8473.30per baseboardCN supply: not made in China
    never routed

    Advanced-computing ECCN 3A090/4A090. A PRC entity cannot lawfully sell these to any destination worldwide, and every credible PRC accelerator vendor is Entity Listed. Never routed.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA L20 48GB (China-market variant)英伟达 L20 48GB
    ComputeHS 8473.30per cardCN supply: not made in China
    classify first

    Designed to sit below 3A090; still requires a documented TPP/performance-density calculation plus a check against BIS is-informed letters before any transaction. Do not rely on vendor marketing.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
  • NVIDIA L2 24GB (China-market variant)英伟达 L2 24GB
    ComputeHS 8473.30per cardCN supply: not made in China
    classify first

    Low-end inference SKU below 3A090 thresholds; still subject to 744.23 supercomputer/advanced-node end-use controls and Entity List screening.

    7 ways buyers get burned here
    • Assuming 'not US-origin' means 'not subject to the EAR'. The Advanced Computing FDPR at 734.9(h) captures foreign-produced 3A090/4A090/.z items made with listed US technology or software, or on a plant derived from it. That covers essentially all leading-edge logic on earth. De minimis analysis never even begins for an FDPR-captured item.
    • Assuming a Chinese trading company can lawfully resell a controlled accelerator abroad. It cannot: 742.6(b)(10)(iii) is presumption of denial for all reexports and for D:5/Macau-headquartered entities, and License Exception ACA at 740.8 expressly excludes entities headquartered in — or ultimately parented in — D:5 or Macau. There is no structure that fixes this.
    • Reading the January 2026 case-by-case rule as 'H200 is now sellable to China'. It permits a LICENSED US EXPORTER to apply, with four certifications including a 50%-of-US-volume cap and mandatory independent US-lab pre-export verification. It changed nothing about reexport from China, and left presumption of denial fully intact for D:5/Macau-headquartered buyers.
    • Believing the AI Diffusion Rule was rescinded and its machinery is gone. It was never rescinded in the Federal Register: 740.27 (AIA), 740.28 (ACM), 740.29 (LPP), Supplement 5 to Part 740 and the 790,000,000 TPP country allocations are all still codified at 2026-09-01. BIS announced non-enforcement of its NEW requirements in May 2025, but the 2026-05-31 guidance confirms the pre-existing November-2023 headquarters-based licence requirement IS enforced, and the 2026-06-17 FAQ extends it to .z items.
    • Treating the Affiliates Rule as dead. It is STAYED, not repealed — 2025-19846 stays the 2025-09-30 IFR until 2026-11-09, roughly two months from now. Build the 50%-ownership aggregation logic now behind a flag. Note also that FDPR footnote 5 already carries its own surviving 50%-ownership provision, and OFAC's own 50% Rule never went away.
    • Screening the brand instead of the legal entity. Entity List designations are entity-specific: 'Inspur (Beijing) Electronic Information Industry' is listed while other Inspur group companies are not, and several distinct Fudan Microelectronics entities were listed separately in September 2025. Screen the unified social credit code on the contract, plus every alias.
    • Ignoring alias sprawl. The September 2025 additions show entities with up to sixteen aliases, and the four NetForward / Nanfei entities were listed across four cities. A single-string name match will miss most of them.
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China Export中国出口