US license
BIS
Beijing approval
procurement + customs
Two-key gate: a US license and Beijing approval both must pass for H200s to reach China
US fab
HBM
GPU die
H200 accelerator
H200 shipments
both keys must pass
Pacific transit
US BIS gate
case-by-case export license
conditional — US capacity,
compliance, security testing
Beijing gate
discretionary approval
discretionary special circumstances
buyers justify vs domestic silicon
China ops
customs can block entry
Only both gates open delivers — Beijing's discretion caps the rebound