Liquid cooling retrofit: CDU capacity is the ceiling on rack density in an existing building (LiquidStack CDU-1MW, up to 1.35 MW per row)

No published price. CDU capacity is quoted per site after a density and cooling-architecture assessment; the vendor's own selector tool gates any number behind a sales conversation.

STRUCTURALLY NOT APPLICABLE, and this is the distinction that matters: the lead time for this record's subject is set by construction, electrical service and cooling/CDU plumbing, not by GPU allocation. The accelerator is not the scarce item, so an accelerator lead time is the wrong question - the record's own notes make this argument. Null here means 'wrong question', not 'no data'.

EAR 742.6(a)(6)(iii)(A) + EAR 744.23/744.6 (Entity, Unverified, MEU list screening of the end user) + the advanced-computing IaaS obligations of 91 FR 1684 (consignee KYC, and management/limitation of IaaS access to the hardware)

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.

RECORDED AS A SUPPLY CHANNEL BECAUSE WHEN YOU CANNOT BUILD A NEW DATAHALL, A CDU IS THE PRODUCT THAT DETERMINES WHAT FITS. LiquidStack publishes the density ceiling of its own hardware, which is the honest upper bound on a retrofit: CDU-1MW 'Supports rack densities up to 1.35MW per row, compatible with next-generation GPU platforms', quick-ship 'live in weeks', with 'In-row and perimeter configurations for new builds and retrofit environments' and 'third-party validated performance and global service through Trane Technologies'. The GigaModular CDU scales 'from initial deployment to multi-megawatt capacity without infrastructure redesign', with N+1/N+2 redundancy, dual-redundant communications, and a thermally important claim: 'Supports 45C return water for chillerless operation - optimized for hyperscale efficiency'. Chillerless operation matters because a colo whose whole strategy is air-cooled chillers (as Vantage's is) can be brought into direct-to-chip service by running the loop warm enough to reject heat without chillers, which is a cheaper retrofit than adding a chiller plant. TREAT THE DENSITY NUMBERS AS VENDOR-MARKETING CAPABILITY CLAIMS, not measured deployments: 'up to 1.35MW per row' is a per-ROW figure across multiple racks, not a per-rack figure, and it is ~11x the 120 kW of a GB200 NVL72 rack, so it is a headroom statement about the CDU class rather than a claim about any specific rack. The vendor names NVIDIA Vera Rubin as a supported platform - the rack-scale generation AFTER the parts in this repo - so treat current-generation fit as inferred from 'next-generation GPU platforms' rather than certified per SKU. The strategic read: CDU vendors are the ones telling you the industry has decided the transition is to liquid, and that the binding constraint on a retrofit is the coolant-distribution hardware, not the server. EXPORT CONTROL (2026-10-04, mechanism-level; sources spl-bis-2026-05-d5-guidance, spl-bis-2026-01-advanced-computing-case-by-case): renting capacity does NOT remove the export-control question, it relocates it. Providing remote access to controlled computing capability can constitute a transfer under the EAR, so the provider must screen the end user; and separately, under the 91 FR 1684 licence regime the consignee must run KYC procedures to prevent unauthorized remote access and must manage and limit IaaS access to the hardware - obligations pushed onto the customer, who must be told to implement them. For a customer headquartered or parented in Country Group D:5 or Macau the 742.6(a)(6)(iii)(A) end-user/parent test can bite even when the capacity is consumed in a permitted region. Recorded true because the underlying hardware is controlled and the provider carries the screening duty, not because access to a US region is itself restricted. LEAD TIME: null - and for this record that is the WRONG QUESTION, which is the point worth recording. This record measures a build constraint that is not the accelerator supply chain: the lead time for a 120 kW liquid-cooled rack is set by construction, electrical service, and CDU/manifold plumbing, not by GPU allocation. Its own notes already make this argument for the colo case, so this entry only fixes the boundary: do not read a GPU lead time into a facility lead time, and do not read a facility lead time into a GPU lead time. No vendor publishes a weeks figure for either, so both stay null - probe log in source spl-negative-no-oem-publishes-lead-time. Where a real published horizon exists for the supply side it is on the accelerator record (NVIDIA's $95.2bn purchase and supply/capacity obligations substantially payable through FY2027, source spl-nvda-10k-fy2026-supply-commitments).