
What Qing knows how to buy — and what it will refuse to
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 →
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.
Each carries the questions that make two quotes comparable, and the traps specific to it
The compute itself (NVIDIA GB200/GB300 class) is US-controlled and is never included. Quote covers the empty thermal/electrical envelope only.
Fluid supply is the binding constraint — see fluorinated fluid item. PFAS restriction in EU/UK makes this a poor choice for European destinations.
If pre-charged with refrigerant, F-gas quota applies at import into the EU.