Export Compliance
Last updated: May 28, 2026
Neural Core Cloud is committed to full compliance with all applicable United States export control laws and regulations, including the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and economic sanctions administered by the Office of Foreign Assets Control (OFAC). This page provides transparency regarding how we classify, control, and restrict the export of our products.
1. EAR99 and ECCN Classification Notice for GPU SKUs
1.1 Standard Products — EAR99
Most of our general-purpose servers, workstations, networking switches, power distribution units, and rack enclosures are classified as EAR99 under the Commerce Control List (CCL). Products designated EAR99 are subject to the EAR but do not require an individual export license for most destinations.
Common EAR99 product categories: standard rack servers, storage arrays, copper/fiber switches, cable assemblies, PDUs, and management software.
1.2 Controlled GPU Products — ECCN Designated
Certain high-performance GPU-based products and components — including full GPU servers, GPU accelerators, and high-bandwidth interconnects — are classified under specific Export Control Classification Numbers (ECCN). The following table provides guidance on our most common ECCN designations:
| Product Type | ECCN | Reason for Control |
|---|---|---|
| NVIDIA H100 / H200 GPU Accelerators | 3A090 | High computing performance (AI/ML workloads) |
| NVIDIA GB200 / B200 Superchips | 3A090 | Advanced AI inference and training performance |
| AMD Instinct MI300X | 3A090 | High-performance AI accelerator |
| NVIDIA HGX Boards / Baseboards | 3A090 | GPU interconnect and aggregate performance |
| Mellanox NDR/HDR InfiniBand Switches | 3A091 | High-speed data transmission (≥ 85 Gb/s) |
| Standard Ethernet Switches & NICs | EAR99 | No control reason (standard commercial grade) |
ECCN designations are provided as general guidance and may change based on product revisions, configuration, or regulatory updates. The authoritative classification is determined by the U.S. Bureau of Industry and Security (BIS).
1.3 What Is EAR99?
Products classified as EAR99 are on the Commerce Control List but do not have a specific ECCN assigned because they are not subject to the same levels of export control as controlled items. EAR99 items may still be restricted from export to embargoed countries (e.g., Cuba, Iran, North Korea, Syria, Crimea region) and to persons or entities on the U.S. government's Denied Persons List or Entity List.
2. Applicable Export Control Regulations
Neural Core Cloud complies with the following U.S. and international export control frameworks:
Export Administration Regulations (EAR)
Bureau of Industry and Security (BIS), U.S. Dept. of Commerce
The EAR regulates the export and re-export of dual-use items — commercial products with potential military applications. Compliance includes proper classification (ECCN or EAR99), end-use checks, and screening against restricted party lists.
International Traffic in Arms Regulations (ITAR)
Directorate of Defense Trade Controls (DDTC), U.S. Dept. of State
ITAR controls the export of defense articles and services listed on the United States Munitions List (USML). While most NCC products fall under the EAR, certain specialized configurations may be subject to ITAR.
Office of Foreign Assets Control (OFAC) Sanctions
U.S. Dept. of Treasury
OFAC administers and enforces comprehensive and sectoral sanctions against targeted foreign regimes and individuals. NCC screens all transactions against the OFAC SDN List, Sectoral Sanctions Identifications (SSI) List, and other restricted party databases.
End-User and End-Use Screening
Multiple U.S. Government Agencies
NCC conducts end-user screening to verify that buyers are not on the BIS Entity List, BIS Denied Persons List, OFAC SDN List, or any other restricted party list. We also screen for prohibited end-uses, including weapons of mass destruction development.
3. Login Gating for Controlled Items
Controlled Products Require Account Verification
Certain high-performance GPU products and components classified under specific ECCNs are not available for direct purchase without a verified buyer account. The following products are subject to login gating:
To access and purchase these products, you must:
- 1. Create a buyer account and provide your business information (legal entity name, tax ID, physical address).
- 2. Complete NCC's compliance questionnaire, confirming your end-use and end-user eligibility.
- 3. Await account approval — typically within 1–3 business days. During approval, NCC may request additional documentation (e.g., certificate of incorporation, proof of address, end-use statement).
- 4. Once approved, you will have access to browse pricing, request quotes, and place orders for controlled items.
⚠ Notice: Attempting to circumvent account verification or provide false end-user information may result in immediate account termination, forfeiture of deposits, and referral to the appropriate U.S. government enforcement agencies for potential violation of export control laws.
4. Restricted Destinations
NCC does not sell, ship, or transfer products to the following restricted destinations without the required U.S. government authorization:
- Cuba, Iran, North Korea (DPRK), Syria — comprehensive embargoed countries
- Crimea, Donetsk, and Luhansk regions of Ukraine
- Any destination subject to a U.S. military end-use or military end-user restriction
- Any person, entity, or transaction listed on the BIS Entity List, Denied Persons List, or OFAC SDN List
5. Compliance Statements and Certifications
Import Statements: No NCC products require import license approval under the customs regulations of the European Union, United Kingdom, Canada, Japan, South Korea, Australia, or other major purchasing jurisdictions for standard commercial transactions.
Anti-Bribery: NCC complies with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and applicable anti-corruption laws in all jurisdictions in which we operate. We do not facilitate or tolerate any form of bribery or improper payments in connection with export transactions.
Human Rights: NCC does not source or sell products that are known to be linked to forced labor, modern slavery, or human rights violations in any supply chain jurisdiction.
6. Export Compliance Contact
For questions about product classifications, export licensing requirements, or end-use compliance, please contact our Export Compliance team:
✉Email: export-compliance@neuralcorecloud.com
📍Address: Neural Core Cloud, Export Compliance Division, 100 Innovation Drive, Suite 400, San Jose, CA 95134, USA