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To check whether a particular NVIDIA GPU is restricted for export to China, identify the exact product and part number, confirm its current export classification, then assess the destination, transaction parties, ownership, end user, end use, and any available authorization. A GPU model name—or a clean screening result by itself—cannot establish whether a shipment is allowed.

This is a transaction-specific check, not a blanket rule for every NVIDIA GPU. Export controls and classifications can change; this guide reflects the materials available as of October 4, 2026. Confirm the current rules before relying on a conclusion for a shipment.

1. Which NVIDIA product is in the transaction?

Record the exact product family, model, and NVIDIA manufacturer part number. Also establish what is being exported: an individual accelerator, a board, or a larger system containing advanced computing integrated circuits. A product name alone may not identify the precise item or configuration under review.

Consumer GeForce, professional RTX, and data-center accelerators are distinct product categories. Do not infer one product’s export status from another’s, even if they share a brand or appear technically similar.

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NVIDIA’s Export Regulations page provides a searchable parts-classification resource with export and import fields, including ECCN entries. NVIDIA cautions that the information is for informational purposes, can change without notice, and is not a representation or warranty that a classification is correct. Treat it as a starting point, not a binding authorization.

2. Is the item subject to the EAR, and what is its ECCN?

Determine whether the item is subject to the U.S. Export Administration Regulations (EAR, 15 CFR parts 730–774), then identify its current Export Control Classification Number (ECCN). An ECCN is a key input to the license analysis; it does not, on its own, say whether a particular shipment may proceed.

The Bureau of Industry and Security (BIS) describes three ways to determine an ECCN:

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  • Ask the manufacturer for the item’s classification.
  • If qualified, classify the item using the Commerce Control List (CCL) and its order-of-review process.
  • Request an official BIS classification through SNAP-R.

Compare manufacturer information with the current CCL because classifications can change. If an item subject to the EAR is not described by an ECCN, it is generally classified as EAR99. EAR99 does not mean “unrestricted”: a license may still be required because of the destination, a restricted party, or the end use. An ECCN is also not a customs tariff code such as an HTS or Schedule B number.

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3. What do the China and destination rules require?

Use the item’s ECCN and its reasons for control with BIS’s current Commerce Country Chart to assess destination-based controls. The chart is a general reference, not a complete answer for an advanced-computing item. Check the current EAR provisions that apply specifically to advanced computing and to China or Macau as well; those provisions may impose requirements beyond what the chart alone shows.

Do not assume that a product is permitted because the chart appears not to require a license, or restricted solely because it is an NVIDIA GPU. The conclusion depends on the exact item, applicable EAR provisions, destination, and the rest of the transaction.

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4. Who is involved, and what will the item be used for?

Identify and screen all parties—not just the buyer—including the purchaser, ultimate consignee, end user, and other relevant intermediaries. Use the U.S. government’s Consolidated Screening List entry point and check the applicable BIS lists. A name-screening result is only one part of the review.

Document the ownership chain, including the location of the ultimate parent, and establish the actual end user and intended end use. Consider relevant remote access, diversion risk, and what the parties know about the transaction’s ultimate destination or purpose.

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In guidance dated May 31, 2026, BIS said a license requirement applies to specified advanced-computing items exported to an entity headquartered in Country Group D:5 or Macau, or whose ultimate parent is headquartered there, even when the entity itself is located elsewhere. Apply that guidance to the parties and item at issue rather than treating the buyer’s location as the only relevant location.

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BIS’s AI counter-diversion guidance also describes controls that may be triggered when a party knows of certain military-intelligence or weapons-of-mass-destruction-related AI-training uses. Assess the actual end use under the current rules; a buyer’s general description of its business may not answer that question.

5. Is there a license requirement or a valid authorization?

After confirming the classification, destination, parties, ownership, end user, and end use, consult the current EAR for any license requirement, review policy, and applicable license exception or other authorization pathway. BIS’s Part 740 describes license exceptions as authorizations that can permit exports or reexports of otherwise license-required items only when their stated conditions are met. Verify that the specific transaction qualifies and that all applicable terms can be satisfied.

BIS announced on January 13, 2026, that it would consider export-license applications for NVIDIA H200, AMD MI325X, and similar chips case by case if specified security conditions are met. The announcement described conditions applicants must demonstrate, including customer compliance procedures and independent testing. It is a conditional review policy—not a blanket approval, proof that a particular shipment has a license, or permission for unrestricted sales. The applicable final rule and current EAR text govern the transaction.

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BIS has also reported that an eligibility timeline for certain authorized integrated-circuit designers was extended through December 31, 2026. This is a time-limited detail, not a general authorization for GPU exports; verify that any relevant pathway remains available and applies to the transaction.

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6. What should you document before deciding?

Keep a record that ties the item-level and transaction-level findings together. At minimum, document:

  • Product family, exact part number, configuration, and whether the item is a chip, board, or system.
  • EAR status, ECCN, classification source, and the date you checked the current CCL.
  • Destination and the applicable country-chart and product-specific EAR analysis.
  • All relevant parties, screening results, ownership and ultimate-parent location, end user, and end use.
  • The license requirement determination and, if relying on an exception or other authorization, how the transaction meets its terms.

If those facts do not support a clear determination, refer the transaction to your organization’s export-compliance team or qualified export-control counsel, and seek BIS guidance where appropriate. Without a specific part number and transaction details, no shipment-specific licensing conclusion can be made.

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