Cross-border trade and compliance

Advanced computing items — accelerators and the systems built around them — are listed under item 3A090 in Annex I of Regulation (EU) 2021/821. An export licence is required to move them out of the customs territory of the EU. Transfers between EU member states require a licence only for items listed in Annex IV, and 3A090 is not among them. Annex I was last amended by Delegated Regulation (EU) 2025/2003, in force since 15 November 2025.

Items of US origin remain subject to the US Export Administration Regulations after they leave the United States, including re-exports and transfers between two non-US companies. Under BIS guidance of 31 May 2026, a licence is required for transfers to entities headquartered in Country Group D:5 or Macau, or whose ultimate parent company is headquartered there — even where the entity itself sits elsewhere. In practice this means the ownership structure of the buyer is checked, not only its address.

What changed in export control of advanced chips sets out both regimes with sources.

Counterparties, their owners and the delivery route are screened against the EU consolidated sanctions list, the US Consolidated Screening List and the UK sanctions list before a quotation is issued.

• Identity and registration of the buying or selling entity
• Ultimate beneficial owner and ultimate parent company
• End user and stated end use
• Delivery address, route and any intermediaries
• Sanctions and restricted-party lists

• End-user statement, signed
• Ownership structure of the buying entity
• Delivery address and intended installation site
• Intended use

• Transactions routed through intermediaries in jurisdictions with elevated diversion risk
• Requests to remove, alter or relabel product identification markings
• Cash settlement
• Transactions where the end user cannot be named

Business-to-business supplies between EU member states are invoiced under the reverse-charge mechanism; the buyer's VAT number is verified in VIES and the verification is kept on file. Domestic supplies carry local VAT. Exports outside the EU are zero-rated against proof of export.

Exports leave with an export declaration, EORI numbers of both parties, tariff classification and the Incoterms stated in the contract. We arrange the documentation; we do not provide legal advice, and buyers remain responsible for import formalities in the destination country.