What does Gatewell USA do for ITAD firms, recyclers and resellers?

Gatewell USA builds export compliance programs for IT asset disposition firms, recyclers and resellers of used data center hardware. It also sells their inventory through to vetted buyers on commission. Los Angeles, California.

The work is for US IT asset disposition firms, e-scrap recyclers, and resellers of used servers, GPUs, storage and network equipment. The two services are taken separately or together. One writes down how equipment is classified, screened, sold and shipped. The other finds buyers for inventory already on the floor.

A used or refurbished item is subject to the Export Administration Regulations exactly as a new one. Classification follows technical parameters rather than age (15 CFR 734.3). That is the starting point for both services.

It opens with a diagnostic of how equipment is classified, screened, sold and shipped today.

What follows is a written export compliance program. It contains the classification procedure for used equipment, restricted-party screening, the customer certification and red-flag check, the headquarters and ultimate-parent check, a procedure for Common High Priority List items, a scrap export procedure, recordkeeping and staff training.

The program is written to fit the legal compliance plan an R2v3 facility already keeps under Core Requirement 4 and the transboundary shipment check in Appendix A. Per-deal review and retained support run once it is in place.

We find buyers for a client's inventory on commission under a written agency agreement. The client remains the seller and the exporter of record. Every buyer we bring is verified and screened by us as well as by the client.

Advanced computing items, the GPUs and GPU servers controlled under ECCN 3A090, 4A090 and the related .z entries, are sold through wherever the sale is lawful. Each deal carries the customer certification, the headquarters and ultimate-parent check and the red-flag record, and where the destination needs an export license nothing ships until the license is in hand.

We do not certify facilities, we do not give legal opinions, and we do not represent a company before a government agency. R2 and e-Stewards certification comes from their certification bodies.

On a deal that carries both a review and the sell-through, the two run behind an information wall. Two people hold the two roles. The reviewer does not see the agency file or the commission. The agent does not see the review file before the reviewer's decision reaches the client. Each decision stands on its own record, and nobody at the firm overrules either one. The arrangement is written into both agreements. What we learn about a client's buyers, sources and prices stays inside that engagement.

• The export compliance program build, what the diagnostic looks at and what the written program contains.
• Sell-through on commission, how the agency agreement works and who checks the buyer.
• Does a used GPU need an export license?
• Exporting e-scrap after the Basel amendments
• Used servers and switches on the Common High Priority List

An engagement starts with the form at /practice-inquiry.