Forty technologies, one form, 30 days

China's Ministry of Commerce and Ministry of Science and Technology on Friday proposed adding 40 technologies to the country's catalogue of technologies prohibited or restricted from export, 23 of them in artificial intelligence. In Announcement No. 48 of 2026, the ministries also require exporters of the listed technologies to register before exporting, with effect from the date of the announcement. Public comments are open from 16 October to 15 November.

The 40 items comprise 23 in AI, covering large models, agents, computing clusters and information processing, five in biomedicine and 12 in photovoltaics, according to the announcement. A ministry spokesperson's question-and-answer says 14 of the 40 would be prohibited and 26 restricted, describes the revision as routine work under the foreign trade law, and says it is not aimed at any particular country, region or entity. The spokesperson said the AI controls are meant to prevent misuse and keep AI under human control.

The draft catalogue, published as an annex to the notice, sets out the model thresholds. The core technology of a large model, which it defines to include weights, key checkpoints, underlying source code and architecture, as well as training-optimisation and inference-acceleration techniques, would be restricted if the model meets any one of three tests: training compute of at least 10²⁶ floating-point operations, at least two trillion parameters, or "globally leading" capability. The annex defines the last as ranking in the global top 10 in public evaluations by mainstream assessment bodies or large platforms at the time of export. Models that provide services after training on what Chinese law classes as "important data" would also be restricted, and those trained on "core data" prohibited. The draft names no companies or models.

The annex goes beyond models. Restricted AI chip design know-how, including architectures, instruction sets, IP cores and software stacks, is defined by a list of features, any one of which qualifies, among them a 14-nanometre or finer manufacturing process, 2.5D or 3D advanced packaging and high-speed interconnects. Some 3D flash and DRAM memory designs are also listed. For computing clusters, interconnect, fault-tolerance and scheduling technologies are covered when used in a "large-scale intelligent computing cluster", which the annex defines as one with more than 10,000 AI accelerator cards. Agents are restricted above set performance levels, such as breaking an instruction into 20 or more sub-tasks, and prohibited for high-performance use in critical infrastructure, defence and core government systems. AI-driven generation of malicious code would be prohibited and AI-assisted vulnerability discovery restricted.

The registration rule is the part that applies now. Until the revised catalogue takes effect, exporters must register on the ministry's online platform before exporting a listed technology, including exports that have started but are not finished. Registration covers transferring ownership of a technology abroad, licensing it for use overseas, and a change of a domestic technology's owner or actual controller to a foreign entity. The form asks for the exporter and recipient, the destination, the technology and its intended use, and the expected export value. The spokesperson said exporters must judge for themselves whether a technology falls within scope.

The ministries drew the line around transfers of the technology, not use of the products. Technology already in the public domain through open-source release or academic publication is excluded, according to the announcement. The spokesperson said that offering a restricted model through an API, an app or website, software-as-a-service or a lightweight on-device deployment is not a technology export; deploying it locally overseas is, although a company running it on its own overseas cloud may qualify for automatic licensing. Automatic licensing would also apply to open-sourcing AI technology, Chinese companies' own overseas computing centres, chip tape-out abroad and joint research, which the ministry describes as close to "report and export immediately".

The proposal follows reporting earlier this year. Implicator, relaying the Financial Times, reported in July that the commerce ministry was consulting Alibaba, ByteDance and Zhipu on limits for model weights and chip designs; Reuters said at the time that it could not immediately verify the report. The Next Web, citing Bloomberg, reported on Friday that some Chinese models already exceed the parameter threshold; Komposite has not confirmed which.

For now the change is procedural: a Chinese lab that licenses weights, or sells a chip design to a foreign customer, files first, and the consultation will decide what is prohibited outright and what needs a licence. Komposite has reported on the Manus deal that China made Meta unwind and on Nvidia's guidance, which assumes no Data Center compute revenue from China. The draft adds Beijing's own rules on what technology can leave China.