China moves to restrict 23 AI technologies and wants exports registered

China moves to restrict 23 AI technologies and wants exports registered

16 October 2026: China's Ministry of Commerce and Ministry of Science and Technology have proposed adding 40 technologies to the country's Catalogue of Technologies Prohibited and Restricted from Export, 23 of them in artificial intelligence. Until the revised catalogue takes effect, any company exporting one of the listed technologies must register the export first on the ministry's trade platform, and that rule applies from the day of the announcement.

Not yet independently verified. We read the announcement and the spokesperson's answers in Chinese on the MOFCOM site. The annex that lists the 40 technologies and their thresholds is a .wps file we have not yet read, so no threshold figure is given here. We will update this when it can be confirmed, and remove this note.

Large models, agents and compute clusters

Announcement No. 48 of 2026 covers three fields. In AI, the 23 technologies relate to large models, agents, computing clusters and information processing. Biomedicine accounts for five (cell and gene therapy, small nucleic acid drugs and pathogenic microbes) and solar for twelve, across polysilicon, wafer and cell manufacturing, including the key equipment that carries those technologies.

The ministry's spokesperson said 14 of the 40 are proposed as prohibited exports and 26 as restricted. The examples given for AI were AI-driven generation and mutation of malicious code, proposed for prohibition, and AI-assisted vulnerability discovery, proposed as restricted. AI technology that has already entered the public domain through open-source release or published academic papers is outside the scope.

Where the line falls for models offered abroad

The spokesperson's answers are the most useful part for software companies, because they say which ways of taking a model abroad count as a technology export. For a restricted AI technology, deploying the model locally in another country is within export control, although deployment on a company's own overseas cloud may qualify for automatic licensing. Offering a restricted model through API calls, an app or web interface, a SaaS product or a lightweight on-device deployment is not treated as a large-model technology export.

Automatic licensing, which the ministry describes as close to "report and ship", is proposed for open-sourcing AI technology, Chinese companies' own overseas computing centres, chip tape-out abroad, joint research using overseas resources and work on international standards. The spokesperson said most AI technology would remain freely exportable once the measures take effect.

Registration starts now

The interim registration covers four kinds of export:

• transferring ownership of a technology abroad, such as assigning intellectual property;
• licensing a domestic technology for use abroad;
• a change of a domestic technology's owner or actual controller to a foreign entity;
• other cases the ministry names by notice.

Exports that have started but not finished are in scope. A registration records the exporter and the recipient, the destination, the technology and its use, and the expected export value, on the technology trade module at ecomp.mofcom.gov.cn. Exporters must judge for themselves whether a technology falls within the list, and the ministry invites questions from companies that run into problems. The third trigger means that a foreign buyer taking control of a Chinese company that holds a listed technology also falls under the registration requirement.

How to comment

Comments on the technologies, thresholds, controls and facilitation measures are open from 16 October to 15 November 2026 by email to jinxianmulu@mofcom.gov.cn, by fax on 010-65197565, or by post to the ministry's Bureau of Security and Control at 2 Dong Chang'an Street, Beijing. Submissions should be marked as comments on the catalogue and give a contact name, organisation and contact details; those sent on behalf of an organisation need its official seal. The announcement gives no date for the revised catalogue to take effect.

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Sources

• MOFCOM and MOST Announcement No. 48 of 2026 (Chinese), 16 October 2026
• MOFCOM spokesperson answers on the catalogue revision (Chinese), 16 October 2026