China
China proposes adding 23 AI technologies to its export control list
China's commerce and science ministries proposed export limits on AI technologies, and exporters must register before shipping them while comment is open.
China has proposed adding 23 AI technologies to its list of banned and restricted exports, and exporters must register before shipping them even while the draft is open for comment.
Two Ministries Propose 40 New Entries
China’s Ministry of Commerce and Ministry of Science and Technology proposed revising the Catalogue of Technologies Prohibited and Restricted from Export in Announcement No. 48, dated Oct. 16. The draft adds 40 technologies across AI, biomedicine and solar power. Comment runs through Nov. 15 by email, fax or letter to the commerce ministry’s security and control bureau.
Of the 40 entries, 23 cover AI technologies for large models, agents, computing clusters and information processing. Fourteen of the 40 would be banned and 26 restricted. The ministry named AI-driven malicious code generation and mutation as a banned technology and AI-assisted vulnerability discovery as a restricted one. Technology already public through open source or published academic papers is excluded.
Registration Applies Now
Exporters must register through the commerce ministry’s technology trade system before exporting any listed technology. The requirement took effect when the announcement was published. It lasts until the catalogue is formally revised. It covers transferring ownership abroad, licensing domestic technology for use abroad, and a domestic technology’s owner or controller changing to a foreign entity. Exports already begun but not completed are included.
Local Deployment Abroad Counts as Export
A ministry spokesperson said Oct. 16 that deploying a restricted AI model locally overseas counts as technology export. Deployment on a company’s own overseas cloud may qualify for automatic licensing. Offering a restricted large model through API calls, an app or web interaction, SaaS or lightweight on-device deployment is not technology export management.
The Ministry Says Most AI Exports Stay Free
The spokesperson said “the vast majority of AI technologies can still be exported freely” after implementation. Automatic licensing, which the spokesperson described as nearly “report and ship,” applies to open-sourcing AI technology, Chinese firms building and running their own computing centers abroad, sending chip designs overseas for fabrication, joint research using foreign resources, and taking part in international standard-setting.
The spokesperson called the revision routine, done under law and not aimed at any country, region or entity. The ministry said AI-driven malicious code could be used against critical infrastructure, defense and core government systems if non-state actors obtained it, and that other major economies also have export controls. The Information and Bloomberg also reported the proposal Oct. 16.
What It Means for the Labs
The draft names no models and no labs. We cannot say which models it will reach. It targets the transfer of technology. We read API access as outside the rules and an on-site install of a restricted model abroad as inside them, whichever models the final list covers. The text can still change before Nov. 15. Registration for listed technologies already applies.