China has proposed adding 23 artificial intelligence technologies to its list of technologies prohibited or restricted from export, while immediately requiring exporters to register covered transfers before they proceed.
The proposal is part of a broader revision covering 40 technologies across AI, biomedicine and solar power, according to a joint announcement issued on October 16 by China’s Ministry of Commerce and Ministry of Science and Technology. Public comments are open through November 15.
AI models, agents and computing infrastructure in scope
The proposed additions span large AI models, AI agents, computing clusters and information-processing technologies. The ministries said 14 of the 40 technologies would be prohibited from export and 26 would be restricted.
Among the proposed prohibited technologies are systems that autonomously generate or modify malicious code, as well as certain core large-model technologies trained with sensitive national data. Proposed restricted items include AI-assisted vulnerability discovery and technologies connected to advanced models, agents and computing infrastructure.
The Associated Press reported that the draft also covers some chip-design technologies, including those used for AI processing and memory chips. It said models with at least two trillion parameters, or with specified globally leading capabilities, could fall under the restricted category. The proposal does not name individual commercial models.
The other proposed additions comprise five biomedicine technologies, including areas related to cell and gene therapy, and 12 solar technologies covering polysilicon, wafers and cell manufacturing. The official announcement said the solar scope can also include key equipment that carries the relevant technology.
Registration starts before final rules
The catalogue revision remains a draft, but the authorities have introduced temporary pre-export registration from October 16 until the final revision takes effect. Covered exporters must submit information through the commerce ministry’s technology-trade platform.
The registration requirement applies to transfers of technology ownership, overseas licensing, changes that place a domestic technology owner or controller under a foreign entity, and other transactions specifically identified by the commerce ministry. It also covers transactions that have begun but are not yet complete.
The filing asks for information on the exporter, the recipient, the destination, the technology and its intended use, and the expected value of the export. Registration is not the same as final approval under the proposed catalogue, but it gives regulators visibility into transfers while the consultation is underway.
Open-source access and cloud services largely excluded
In an accompanying policy explanation, the commerce ministry said technologies already in the public domain through open-source releases or academic publications would not be covered. It also said most AI technologies would remain freely exportable.
For technologies that do fall into a restricted category, overseas deployment may count as a technology export. However, Chinese companies operating their own overseas cloud or computing centers, conducting chip fabrication abroad, undertaking joint research, or participating in international standards work may qualify for simplified or automatic licensing procedures.
The ministry drew a distinction between transferring controlled technology and providing access to services built on it. Overseas use through APIs, websites, apps and software-as-a-service offerings would generally not be treated as a large-model technology export when no restricted technology is transferred. Lightweight deployment on overseas devices would also generally remain outside that scope.
Reuters reported that this distinction could allow Chinese developers to continue serving international users while giving Beijing greater oversight of sensitive model transfers and overseas deployments.
Final scope may still change
The ministries said the proposed controls are intended to prevent misuse, protect national security and keep sensitive AI capabilities under human control. The commerce ministry said the move does not target any particular country, region or entity.
The final catalogue may change after the consultation. Companies involved in cross-border technology licensing, overseas model deployment or changes in control will need to assess both the temporary registration rule and the detailed technical thresholds in the draft annexes.
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