How does selling inventory through on commission work?

We find buyers for a client's inventory on commission under a written agency agreement. The client stays the seller. The invoice, the title and the shipment stay on the client's side of the table.

The work suits a US IT asset disposition firm, e-scrap recycler or reseller of used servers, GPUs, storage and network equipment that has stock moving slower than it wants.

One written agreement comes first. It names the inventory in scope, what we may say about it, how a buyer is introduced and how commission is earned.

We then work the inventory as an agent. We locate buyers, qualify them, carry the specification and the test record to them, and bring back an order for the client to accept or decline. The client prices its own goods.

The client's own program governs the sale. Ours sits on top of it.

The client remains the seller and the exporter of record. That means the client's name is on the invoice, the client's decision releases the goods, and the client's filing covers the export.

Every buyer we bring is verified and screened by us as well as by the client. Two checks run on the same buyer. Ours does not replace the client's. A buyer who clears ours still goes through the client's program before anything ships.

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). A buyer check on used hardware is therefore the same check it would be on new hardware.

Advanced computing items are the GPUs and GPU servers controlled under ECCN 3A090, 4A090 and the related .z entries. We sell those through wherever the sale is lawful, with the checks below run and recorded on every deal.

The buyer signs the customer certification described in the BIS guidance of May 13 2025, which asks sellers to collect the customer's role, intended activity, delivery address and the headquarters of the customer and its ultimate parent. The same guidance lists eleven red flags and seven due diligence actions. Every deal is checked and recorded against them.

The BIS guidance of May 31 2026 says a license is required to export advanced computing items to an entity headquartered in Country Group D:5 or Macau, or whose ultimate parent is, "even if the entities themselves are located outside Country Group D:5 or Macau."

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 inside a compliance engagement stays there. Buyer lists, sourcing and prices are not used to buy or sell for our own account or for another client. Both documents carry that clause.

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