CDW (enterprise IT distributor) - accelerator and GPU-server supply

lead_time_weeks 6 is CDW's own printed window for the accelerator SKUs on this record (RTX PRO 6000 Blackwell Server Edition 96GB '4-6+ Weeks'; L4 '4-6+ Weeks'; ConnectX-7 '1-3+ Days'), read from the product pages on 2026-10-03/04 per source spl-cdw-published-lead-times-gpu-2026-10. 6 is the upper bound of the published '4-6+' range as displayed. Read the '+': the range is open-ended, and a distributor lead time measures THEIR inbound, so it is a lower bound on what a buyer faces - the same 4-6+ window also appears on non-GPU items (a QNAP NAS, an HPE GPU enablement kit), which is the tell that it is a distribution lead time as much as part scarcity.

EAR 742.6(a)(6)(iii)(A) + EAR 744.23 (Entity List) + EAR 744.6 (Unverified / MEU lists) + EAR Regional Stability (RS) controls for Country Groups D:1, D:4, D:5 (88 FR 73458, Oct 2023)

LAYER 1, EXPORT LICENCE: under the Jan 2026 BIS rule 91 FR 1684 (effective 2026-01-15) the license review policy for advanced-computing commodities with TPP < 21,000 AND total DRAM bandwidth < 6,500 GB/s - the NVIDIA H200 and AMD MI325X are the rule's named examples - moved from PRESUMPTION OF DENIAL to CASE-BY-CASE REVIEW, but only for exports FROM THE UNITED STATES to end users located in China or Macau, and only against six exporter certifications filed via SNAP-R before shipment: (1) items below the thresholds with the count of units shipped in the US; (2) sufficient US supply, judged 'taking into account normal lead times'; (3) no diversion of global foundry capacity away from US end users; (4) aggregate China+Macau shipments <= 50% of total US end-use shipments of that product; (5) no end-user or use prohibition; (6) the consignee runs rigorous KYC. Every shipment must then pass a qualified third-party testing lab - US-headquartered, not controlled by a D:5/Macau entity, no ownership stake in any party, qualification revocable by BIS at any time - verifying TPP, total DRAM bandwidth, interconnect bandwidth and copackaged DRAM capacity. Reexports and in-country transfers of the same chips to China/Macau REMAIN PRESUMPTION OF DENIAL. LAYER 2, END-USER AND PARENT SCREENING: per BIS guidance of 2026-05-31 a licence is required where the consignee is HEADQUARTERED in Country Group D:5 (15 CFR part 740 supplement no. 1) or Macau OR whose ULTIMATE PARENT COMPANY is so headquartered - even when the consignee itself sits outside D:5/Macau. The requirement sits at EAR 742.6(a)(6)(iii)(A) for destinations outside the US, with an exception available only under the license exception at 740.2(a)(9)(ii). The destination country alone therefore never answers the question; screen the parent. LAYER 3, REMAINING LIMITS: exports to D:5/Macau-headquartered OR -parented entities stay PRESUMPTION OF DENIAL wherever the buyer sits, and the AI Diffusion Rule that would have set a country-tier structure on who could lawfully buy what was RESCINDED on 2025-05-13 and is not being enforced, so any recorded status rests on the instruments named here rather than on tiering. UPGRADE NOTE: this record's earlier text cited only the Oct 2023 interim final rule (88 FR 73458) and a presumption of denial, with no paragraph and no mechanism. That is retained here as history: what changed is that the Jan 2026 rule (91 FR 1684) carved the TPP < 21,000 / DRAM < 6,500 GB/s band - which includes the H200 and MI325X on this record - out of presumption of denial into case-by-case review for US exports to China/Macau end users, and that BIS's 2026-05-31 guidance fixed the end-user/parent limb at 742.6(a)(6)(iii)(A).

QUOTE-ONLY for the high-value SKUs; price_usd deliberately null. Process verified on the product pages themselves: 'Get a Quote' / 'Request Pricing' forms requiring name, email, phone and organization, with the stated SLA 'A CDW representative will email you within one business day to confirm your request'. THE MOST IMPORTANT FINDING IN THIS RECORD IS A NEGATIVE ONE: a CDW catalog search for 'NVIDIA H100' returns 676 hits, but the entire 'Servers & Server Management' facet is only 8 items and the accelerator content is L40S, L4, RTX PRO/6000 Ada, RTX 5000 Ada, RTX A1000/A400, BlueField-3 and ConnectX - i.e. CDW stocks workstation and inference-class PCIe cards and the DGX, and does NOT list H100/A100/H200 SXM modules at all. The 353 items in the '$3000 and above' bucket are almost entirely servers and complete systems, not accelerator modules. So 'CDW carries H100' is false at the module level; the real question is whether a DGX or HGX system can be quoted, and DGX B200 8x180GB is listed (CDW # 8055598, mfg DGXB-G1440+P2CMI36, includes full 3-year support) at quote-only. OBSERVED LEAD TIMES from the product pages (2026-10-03): RTX PRO 6000 Blackwell Server Edition 96GB '4-6+ Weeks'; ConnectX-7 '1-3+ Days'; RTX 6000 Ada 48GB shown as 'discontinued on October 3, 2026' - a live example of a datacentre GPU SKU ageing out of a distributor catalogue inside a product generation. CDW's own price filter note ('Does not show contract pricing or discounts') plus the absence of any price on the accelerator pages is why nothing is recorded numerically. EXPORT CONTROLLED (true). Regime: US BIS advanced-computing export controls (the Oct 2023 interim final rule, 88 FR 73458 - source sup-buy-bis-2023-advanced-computing-controls), which put datacenter accelerators under ECCN 3A090/4A090, added the advanced-computing Foreign Direct Product (FDP) rule, and extended Regional Stability (RS) controls to Country Groups D:1, D:4 and D:5. For items destined to Macau or Country Group D:5 the rule applies a PRESUMPTION OF DENIAL; other RS destinations get a presumption of approval. Practical effect: which accelerator you can legally be sold, and which SKU counts as compliant, is set by destination and end user - not by the channel. LEAD TIME 2026-10-04 re-verification: the previously recorded observations still hold on this date - RTX PRO 6000 Blackwell Server Edition 96GB '4-6+ Weeks', ConnectX-7 '1-3+ Days', RTX 6000 Ada 48GB discontinued 2026-10-03. New datapoints from the same fetch: NVIDIA RTX PRO 4500 Blackwell Server Edition (MFG 900-2G147-0000-000, CDW 9077550) at '9-11+ Days' and NVIDIA A16 64GB GPU computing processor (R8T26C, CDW 7342826, $9,277.99) at '10-12+ Days' - both materially faster than the 96GB part, which is the availability gradient across the RTX PRO 6000 family. DGX Spark (NVDGXSPARK-PB) is 'Item Backordered' with no window. The record's lead_time_weeks of 6 remains the midpoint of the published 4-6+ Weeks window on the 96GB Server Edition line and is an inference from a range, not a quote. EXPORT CONTROL REGIME: SCHEME RECLASSIFIED (2026-10-04): was a bare boolean plus 'EXPORT CONTROLLED (true). Regime: the Oct 2023 interim final rule, 88 FR 73458' with no paragraph, no mechanism and no expiry. Now recorded as a citation plus the three-layer mechanism.