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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →You cannot tell whether an AI GPU or server can be exported to China from its product name alone. Check whether the item is subject to the U.S. Export Administration Regulations (EAR), establish its current ECCN and technical parameters, then assess the destination, all parties and their ownership, end use, delivery and installation sites, and any indirect or cloud access. Only after those checks can you determine whether a license is required or a specific license exception is available. This is a transaction-specific workflow, not a ruling on any particular shipment.
Start by defining what the transaction actually does
Before looking up a GPU or server, record the transaction path. A shipment from the United States, a reexport from another country, a transfer within a country, an upgrade to an installed system, and remote access to computing capacity raise different factual questions. Include who will receive, install, own, operate, and use the equipment—and who may access it remotely.
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| Transaction path | Facts to establish |
|---|---|
| Export from the United States | Exporter, purchaser, intermediate and ultimate consignees, destination, end user, intended use, delivery address, and installation site. |
| Reexport or in-country transfer | Current location and classification of the item; parties to the onward shipment or transfer; new destination, end user, and use. |
| Components or upgrade for an existing system | Exact components or software, the system being upgraded, where it is installed, who controls it, and its intended use after the change. |
| Data-center or IaaS access | Provider, customer, remote users, physical location of the equipment, who controls access, and whether capacity will be used to train AI models for or on behalf of another party. |
For each path, identify the ultimate consignee and end user rather than treating the ship-to address as the full answer. Record the customer’s headquarters and ultimate parent as well as the equipment’s delivery and installation locations.
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BIS’s licensing workflow begins with jurisdiction: determine whether the commodity, software, or technology is subject to the EAR. Do not assume that a system is outside the rules just because it was made or shipped outside the United States; foreign-made items can require a separate jurisdictional analysis under the EAR. The available facts here do not resolve the status of any particular foreign-made system.
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- Professional Intel Arc Pro B70 GPU: Built on the Intel Xe2-HPG architecture, it features 32 Xe cores and 256 XMX engines, designed to accelerate AI, rendering, and complex visualization workloads.
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If the item is subject to the EAR, continue with classification and transaction review. If you cannot establish jurisdiction confidently, get qualified export-compliance advice before treating the item as outside U.S. controls.
Establish the current ECCN and technical basis
Ask the manufacturer, producer, or developer for the item’s Export Control Classification Number (ECCN) and the technical basis for it. Confirm that the classification applies to the exact item being transferred: a chip, board, assembly, complete server, software, or technology may not share one classification. BIS’s Classify your item guidance says ECCNs can change, so check the current Commerce Control List (CCL) rather than relying on an old vendor document or a model name.
- Collect the datasheet and the technical parameters relevant to the item’s CCL entry.
- Compare the manufacturer’s ECCN and supporting rationale with the current CCL and its notes.
- If self-classifying, use the CCL Order of Review and ensure the person doing the work understands the hardware and relevant parameters.
- If the classification is uncertain or consequential, request a BIS classification through SNAP-R.
An item subject to the EAR but not described by an ECCN on the CCL may be EAR99. That is a classification outcome, not permission to export: destination, end-user, end-use, and other controls may still apply.
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Check advanced-computing controls for the exact item
For AI accelerators and servers, examine the current EAR entries and notes that may apply to the precise chips, boards, assemblies, and complete computer. BIS’s May 13, 2025 guidance, Controls that May Apply to Advanced Computing Integrated Circuits and Other Commodities Used to Train AI Models, identifies 3A090.a, 4A090.a, and related “.z” entries as potentially relevant. Its examples include servers classified under 5A992.z.
Those examples do not classify every GPU or server. The result depends on the item’s technical parameters and the applicable entry. Review the live CCL and the complete current control text; do not infer the classification from a marketing label, vendor family, or another product in the same server line.
Assess China, headquarters, and ultimate ownership
Review both the destination and the customer’s corporate structure. BIS guidance dated May 31, 2026, titled Guidance Regarding Enforcement of License Requirements for Advanced Computing Items for Entities Headquartered in Country Group D:5 and Macau, says the license requirement continues for specified advanced-computing items destined outside the United States for entities headquartered in Country Group D:5 or Macau, and for entities whose ultimate parent is headquartered there. The guidance says exporters should seek a license unless a license exception specified in the EAR is available.
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For a China-related transaction, verify the applicable country group and regulatory text at the time of the transaction, then establish the customer’s headquarters and ultimate parent. A shipment routed through a third country or addressed to a company located elsewhere does not answer the ownership question. The 2026 guidance addresses specified advanced-computing items and covered entities; it is not a blanket statement that every AI GPU or server shipment to China is prohibited.
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Screen the parties and investigate end use and indirect access
Use BIS’s Consolidated Screening List (CSL), linked from its About Licensing resource hub, and review current end-user and end-use restrictions. Screening is one part of due diligence; a clean name match result does not by itself establish that a transaction is authorized.
- Check the purchaser, intermediaries, ultimate consignee, end user, data-center operator, and relevant parent entities.
- Confirm the customer’s business, incorporation date, headquarters, ownership, and ultimate parent against the proposed order and use.
- Confirm where equipment will be delivered and installed, who will operate it, and who will have remote access.
- For an IaaS or data-center arrangement, identify the customer and any party for whose benefit the computing capacity will be used.
- For AI training, determine whether a provider or another party will train models for or on behalf of a D:5- or Macau-headquartered party, and whether restricted WMD or military-intelligence users or end uses are implicated.
BIS’s May 2025 guidance identifies potential controls in specified advanced-computing and IaaS scenarios when the requisite knowledge and conditions are present. It also flags diligence concerns such as an unknown ultimate installation address, missing headquarters information, a data center without the power, cooling, or space for the equipment, or an IaaS provider unable to affirm that users are not China-headquartered. Treat these as reasons to investigate and resolve gaps, not as automatic legal conclusions.
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- System Compatibility Note: 2-slot card, 271x112x39mm, single 8-pin power, 200W TDP. Verify chassis clearance and PSU capacity before purchase.
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- 24GB GDDR6 on 192-Bit Bus: Massive 24GB memory with 456 GB/s bandwidth – ideal for LLMs, AI inference, 3D rendering, and generative design.
- Intel Xe2-HPG Architecture: Built on Intel's next-gen architecture with 20 Xe cores and 160 XMX engines for AI acceleration (197 INT8 TOPS).
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Determine whether a license is required or an exception truly applies
Apply the current EAR provisions to the item, destination, parties, end use, and transaction path together. BIS’s May 2026 guidance describes the continuing licensing requirement for the covered advanced-computing items and entities unless a license exception specified in the EAR is available.
EAR Part 740 includes advanced-computing-related exceptions such as NAC and ACA. Their names do not create blanket authorization: each has specific eligibility, item, destination, notification, and other conditions. Read the operative text in force for the transaction, verify every applicable condition, and retain the analysis. If you cannot establish that an exception covers the exact item and transaction, do not rely on it.
If a license appears necessary, or a consequential classification remains unresolved, use SNAP-R to submit a BIS license application or classification request as appropriate. Do not ship based only on a supplier’s assurance, a general chart, or an exception name.
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Keep a defensible decision record
Preserve the information that supports the jurisdiction, classification, screening, end-use, and authorization decisions. A useful file includes:
- Technical datasheets, the ECCN, and the classification rationale, including the CCL entry and version checked.
- The EAR provisions and guidance consulted, with the date of review.
- Names and roles of transaction parties, screening results, headquarters and ownership information, and the ultimate parent.
- End-use details, end-user statements, delivery and installation addresses, and relevant cloud-customer or remote-access arrangements.
- The license exception analysis and evidence for each condition, or the license and any relevant BIS correspondence.
Because the EAR text and enforcement guidance can change, verify the rules again before a real transaction. This workflow is general compliance information, not legal advice or an individualized BIS determination.
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