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IBM System Storage Ideas Portal


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Status Submitted
Created by Guest
Created on Nov 15, 2026

Third-Party Testing Certification Record

PROBLEM: The January 15, 2026 BIS rule that moved H200-class review to case-by-case made approval conditional on exporter certifications — including independent third-party testing in the United States before shipment. That testing condition is the control that is supposed to catch what paperwork vetting missed. There is no certification record of which shipments were independently tested, by whom, and with what result.

SOLUTION: A third-party testing certification record: every licensed shipment logged with its independent test certificate, the testing body, the test date, and the result — so the testing condition is a verifiable record, not a certification checkbox.

EVIDENCE BASIS: DOCUMENTED — BIS rule FR Doc. 2026-00789, Jan 15, 2026: H200, its equivalents and less advanced chips bound for China and Macau moved from presumption of denial to case-by-case review, subject to exporter certifications including independent third-party testing in the United States.

Idea priority Low