China's Ministry of Commerce and Ministry of Science and Technology jointly announced a draft revision to the national catalog of technologies subject to export bans and restrictions on Friday, October 16, 2026. The proposal covers 40 technologies across artificial intelligence, biomedicine, and solar energy, including 23 AI-related items. Public comments will be accepted through November 15, 2026, while a temporary export registration requirement takes effect immediately.
Proposed AI Controls and Exclusions
The AI section includes large models, autonomous agents, computing clusters, and information processing technologies, along with model weights, source code, and chip designs above certain performance thresholds. Exports of core models trained on sensitive national data and agents intended for defense or critical information infrastructure would be prohibited. Models with at least 2 trillion parameters or recognized leading capabilities would be restricted.
The revision also lists five biomedicine technologies, such as cell and gene therapy, small nucleic acid drugs, and pathogen-related systems, and 12 solar technologies covering polysilicon, wafer, cell manufacturing, and key equipment. Technologies already disclosed through open source or academic publications are excluded from management. The commerce ministry confirmed that public technologies would not fall within the export control scope.
Registration and Transfer Obligations
From the announcement date until the final catalog is implemented, exporters of listed technologies must register before export through MOFCOM's unified technology trade management platform. The requirement applies to ongoing transfers that have started but are not yet finished, including intellectual property transfers, overseas licensing, and ownership or effective control changes in favor of foreign entities. Registration must include exporter and recipient details, destination, intended use, and estimated export value.
The authorities clarified that offering access through an API, application, webpage, or software as a service does not by itself constitute exporting model technology. Transferring a restricted technology for deployment abroad can be regulated, with facilitation available for scenarios such as dedicated cloud environments. Using a Chinese AI system online therefore differs from receiving the underlying technology to operate overseas.
Public Feedback and Industry Impact
Interested parties can submit comments by email, fax, or mail until November 15, 2026. Feedback may address the proposed technology scope, performance indicators, control policies, and facilitation measures for all listed categories. Submissions should include the contact person, organization, and contact details, while comments filed by organizations should carry an official seal.
Chinese AI models including Moonshot's Kimi K3 and Alibaba's Qwen 3.8-Max are among systems with parameter counts exceeding 2 trillion, though the draft does not name specific models. The proposed list also covers several chip design technologies for AI processing and memory chips. Solar-related controls include key equipment that carries manufacturing technologies for polysilicon, wafers, and cells.
Strategic Context and Rationale
The draft arrives after years of U.S.-led export controls that have limited China's access to advanced AI chips and chipmaking equipment. It also follows progress in U.S. and China dialogues on AI safety, governance, and a notification mechanism for AI incidents that could threaten national security. Analysts described the move as a response to Western technology sovereignty requirements in strategic sectors.
A Ministry of Commerce spokesperson said the measures are necessary to reinforce security boundaries, prevent misuse and abuse, and ensure AI remains under human control. Officials said the review does not target a specific country or company. They also cited risks such as malicious cyber operations in sensitive areas as a reason for export controls.
The consultation closing on November 15 does not automatically enact all proposed restrictions, and the final revision date remains unannounced. For users outside China, the measure does not impose a general block on Chinese AI applications, while companies receiving technology must evaluate how their operations align with the final rules. The announcement highlights China's tightening control over advanced technology transfers amid ongoing strategic competition.