The work that happens between the purchase order and the rack.

The questions your compliance team will ask, answered before they ask them.

Hong Kong is a normal node in an Asian supply chain and an abnormal one in a European or American risk assessment. Pretending otherwise wastes everyone a fortnight. So here is our position on each of the things a buyer in Munich, Manchester or Denver has to clear internally before a purchase order can be raised. None of it is a certification. All of it is checkable against what we put on your paperwork.

Export control

Since 2020 the US treats Hong Kong as China under the Export Administration Regulations. Anything that needs a licence to China needs one here. We work inside that rather than around it: every consignment moves under a Hong Kong strategic-commodities licence where the classification calls for one, and we obtain and keep evidence of lawful prior export for US-origin goods. Advanced-computing accelerators in the controlled classifications are quoted only against full end-user documentation and a licence where one is required — if that documentation is not forthcoming, we decline the order rather than restructure it.

Stated per line, before you commit

The quotation carries the export control classification and the country of manufacture for every line on it. You get both before you raise a purchase order, not after your broker asks.

Screening

Every counterparty, consignee and stated end user is screened against the OFAC, BIS Entity and Denied Persons, EU consolidated, UK and Hong Kong lists before anything is released. We do not accept transshipment or reconsignment to a third country that was not named on the original order, and we ask who the goods are for on any restricted category. Being asked is not an accusation; it is the reason we can ship at all.

Chinese-origin hardware

We carry xFusion, which is Huawei’s former x86 server business, spun out in 2021, and we carry Huawei storage and compute. If your procurement policy excludes Chinese-origin server hardware, or you are a US federal contractor subject to NDAA §889, these lines are not for you and we will say so on the first call rather than the last. Everything else in the index is unaffected.

Origin and customs value

Origin means where the unit was manufactured, not that it left from Hong Kong — a distinction that decides what you pay. We give the HS code and the manufacture origin per line so your broker can price the landed cost before you commit. We declare the true transaction value on used goods. We do not under-declare, and we do not mark commercial shipments as gifts or samples, whoever asks.

WEEE and RoHS

If you import from us into the EU or the UK, you are likely the party placing the equipment on that market, which can bring producer registration and reporting duties with it. We supply per-line weights and equipment category data so you can report, and the invoice states whether each line is new or used. We pass through the manufacturers’ declarations where they exist. We do not issue declarations of conformity of our own, and we cannot take on your producer obligations — anyone who tells you otherwise is selling you a problem.

Anti-bribery

No facilitation payments, in any jurisdiction, for any reason. No agent is paid a success fee without it being disclosed to you. We will sign your supplier code of conduct.

This is our operating position, not legal advice, and none of it substitutes for your own counsel or your own customs broker. Where a rule has moved recently — and several in this area moved repeatedly through 2025 and 2026 — we would rather tell you that than quote you a figure that expires inside a quarter.