Are used servers and switches on the Common High Priority List?
The headings they are imported and exported under are. On the BIS Common High Priority List, HS 8517.62 for network equipment is Tier 2 and HS 8471.50 for processing units, which covers servers, is Tier 3.A.
BIS developed the list with the European Union, Japan and the United Kingdom. It names 50 items by six-digit HS code that Russia seeks to procure for its weapons programs. A reseller of used data center hardware handles both of these headings in ordinary trade. The list does not sort by condition. 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).
The two headings and their tiers
HS 8517.62 covers network equipment. It sits at Tier 2.
HS 8471.50 covers processing units. Servers fall under it. It sits at Tier 3.A.
Those are two headings a reseller meets in a rack teardown. Storage, power and cabling travel under other headings, which the same procedure identifies before a quote goes out.
What a listed heading means for screening
It means the heading is the subject of a written step rather than a judgment call at the loading dock.
In a program we build, a listed heading triggers the same sequence every time. The heading is identified on the item before the item is offered. The buyer is screened. The customer certification is collected. The red-flag check is run and recorded against the deal. The file closes with a record of what was checked and who checked it.
Nothing about that sequence depends on who is standing at the shipping desk that day.
What the customer certification collects
For advanced computing items, the BIS guidance of May 13 2025 asks sellers to collect a certification naming the customer's role in the transaction, its intended activity, the delivery address, and the headquarters of the customer and of its ultimate parent. The same guidance lists eleven red flags and seven due diligence actions.
The headquarters field carries weight of its own. 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."
The May 13 2025 guidance closes with this sentence. Exporters "may not self-blind to avoid license requirements."
Where this sits in a written program
The Common High Priority List procedure is one element of the export compliance program, alongside the classification procedure for used equipment, restricted-party screening, the customer certification and red-flag check, the headquarters and ultimate-parent check, the scrap export procedure, recordkeeping and staff training.
For an R2v3 facility, all of it is written into the legal compliance plan kept under Core Requirement 4 and the transboundary shipment check in Appendix A.
We build the procedure, support classification, screen the buyer and keep the record. A legal opinion or an enforcement matter is a lawyer's work, brought in when a matter needs it.
The program build is described at export compliance program for used IT hardware. To start, use the form at /practice-inquiry.
Questions
Which tier is a used switch?
The heading is what carries the tier. HS 8517.62 for network equipment is Tier 2 on the Common High Priority List.
Which tier is a used server?
HS 8471.50 for processing units, which covers servers, is Tier 3.A on the Common High Priority List.
Does a listed heading mean we cannot sell the item?
The listing is a screening subject rather than a conclusion about a sale. What the program does with it is a written sequence, which runs the heading, the buyer, the certification and the red-flag check before anything is shipped.
Does refurbishing move an item off the list?
The heading follows the item, not its condition. A used or refurbished item is subject to the Export Administration Regulations exactly as a new one (15 CFR 734.3).
What do we ask a buyer to sign?
For advanced computing items, the certification described in the BIS guidance of May 13 2025, which names the buyer's role, its intended activity, the delivery address and the headquarters of the buyer and of its ultimate parent.
Can you write this procedure for our team?
Yes. It is one element of the program build. Training for the people who run it comes with it. Start with the form at /practice-inquiry.
Start an inquiry We reply within two working days, with a quote or with the questions we need answered first.