The Pulse
China Requires AI Export Registration as It Drafts New Curbs
China proposed adding 40 technologies, including 23 AI technologies, to its restricted-export catalogue and began requiring exporters to register covered transfers. The draft spans AI models, agents, computing clusters and chip designs, whi
AI.info Team · Written with AI ·
“此次修订亦是技术贸易管理的常态化工作，依法依规进行，不针对任何特定国家、地区或实体。”
Ministry of Commerce spokesperson
China’s Ministry of Commerce and Ministry of Science and Technology said their proposed technology-export catalogue revision is routine and not aimed at any particular country, region or entity. The draft, announced October 16, would add technologies in artificial intelligence, biomedicine and solar photovoltaics to the country’s list of prohibited or restricted exports.
The proposal is not yet final, but a separate requirement has already begun: exporters must register covered technology transfers before export. The two ministries are accepting public comments on the proposed catalogue through November 15.
23 AI technologies enter the draft
The ministries’ announcement covers 40 technologies across three fields: 23 related to AI, five to biomedicine and 12 to photovoltaics. The AI categories include large models, intelligent agents, computing clusters and information processing. Bloomberg Law reports that the draft also names chip designs, and that model weights and source code for products above specified performance thresholds could fall within its scope.
The 40 proposed additions are divided between 14 technologies slated for a ban and 26 proposed for restrictions, according to the ministry spokesperson. The spokesperson cited AI-driven generation and modification of malicious code as an example of a technology proposed for prohibition, and AI-assisted vulnerability discovery as an example proposed for restriction. Those totals cover the three fields together, not AI alone.
Registration starts before the catalogue is final
Until the revised catalogue takes effect, exporters must register technologies listed in the October 16 announcement before transferring ownership abroad, licensing domestic technology for overseas use, or changing a technology’s owner or actual controller to a foreign entity. The requirement also covers exports already underway but not completed. Registration asks for information such as the exporter, recipient, destination, intended use and expected value of the technology transfer.
The consultation period and the registration period serve different purposes. The public can comment on the proposed additions and their technical thresholds through November 15, while the interim registration requirement applies from the announcement date until the revised catalogue formally takes effect.
MOFCOM draws a line around model services
The ministry’s explanation distinguishes technology transfers from several ways of providing AI services overseas. It says that, once the revised catalogue takes effect, overseas local deployment of restricted AI technology would fall within export-management rules. By contrast, the ministry says API access, app or web interactions, software-as-a-service offerings and lightweight on-device deployments of restricted large models would not count as exports of large-model technology.
The ministry also says technologies already in the public domain through open-source releases or academic publications are not included in the proposed controls. For some other cases—including open-source AI work, companies building and operating their own overseas computing centers, overseas chip fabrication and joint research using overseas resources—it describes automatic licensing or other facilitation measures.
The draft sets a boundary, not a final one
Those distinctions matter for Chinese AI companies that distribute model weights, license technology or deploy models abroad. The draft’s stated scope reaches certain model materials and chip designs, while the ministry describes exclusions and expedited routes for other activity. The practical boundary will depend on the technical criteria and final catalogue; the public announcement sets out the consultation and interim registration process but does not settle every case.
For now, companies exporting technologies covered by the announcement face a concrete step before a transfer: register it with the commerce ministry. The public-comment period closes November 15, 2026.