The rule says the third-party testing lab must be headquartered in the United States, the testing must take place in the United States, and the lab must not have any financial interest or ownership in any party to the transaction.

The exact words it rests on

Among the qualifications for a third-party testing lab, it must be headquartered in the United States, not otherwise under the control of a company or other entity headquartered in or whose ultimate parent company or other entity is headquartered in Country Group D:5 or Macau, and the testing must take place in the United States. Further, the lab must not have any financial interest or ownership in any party to the transaction

What the source said when we opened it, on 9 Nov 2026.

The source

Revision to License Review Policy for Advanced Computing Commodities (Federal Register 2026-00789)
Bureau of Industry and Security, US Department of Commerce · 2026-01-15

Open the sourcearchived copy

Checked

Checked by the notis newsroom on 9 Nov 2026, against the source above.

In the story

What the H200 export rule requires before China licences get case-by-case review 9 Nov 2026