China proposes export controls on 23 AI technologies, from large models to chip design

China's commerce and science ministries have proposed adding 23 artificial intelligence technologies to the country's list of restricted exports, covering large models, AI agents, computing clusters and the design of advanced AI chips. The draft is open for comment until November 15, 2026. One part is already live: exporters of listed technologies must register before shipping.

What the notice says

The text is MOFCOM and MOST Announcement No. 48 (2026), dated October 16, 2026, issued through the Ministry of Commerce's Security and Control Bureau with the Ministry of Science and Technology. It asks the public to comment on a revision of China's Catalogue of Technologies Prohibited and Restricted from Export. In total the revision covers 40 technologies in three fields: artificial intelligence, biomedicine and photovoltaics. Twenty-three of them are in AI.

The AI items cover large models, agents, computing clusters and information processing. The notice carves out technologies that have already entered the public domain through open-source release or academic publication. In our reading of the notice, that is the line that decides how much of China's open-weight output is affected.

The interim rule that applies now

Between the announcement date and the day the revised catalogue takes effect, exporters of the listed technologies must register on MOFCOM's technology trade management platform before exporting. The Next Web says this includes deals that are not yet completed. So even before the final text, a Chinese company selling or transferring a covered technology abroad needs to register first.

Comments can be sent by email, fax or mail, referencing the catalogue revision, with a deadline of November 15.

The parameter threshold, with a caveat

The Next Web, citing Bloomberg, reports that the large-model entry applies to models of at least 2 trillion parameters, or those ranking in the world's top 10 on tests of performance and safety. It says Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max are reportedly above that size, and notes the draft does not name any model.

We could not confirm the 2 trillion figure in the notice summary we opened, so treat it as press reporting about the draft until the text is checked line by line.

Chip design is covered too. According to The Next Web, the entry names AI chips made at 14 nanometers or below, or built using 2.5D or 3D chip stacking, along with some memory chip designs.

What stays open

Two carve-outs matter. First, open-source code and published research are exempt. Second, Chinese firms can keep serving overseas users through apps, websites and APIs. The Next Web adds that running a covered model on overseas servers counts as an export, though a firm running it on its own cloud servers abroad could get a license automatically.

That last point is the live fight. Many foreign companies run Chinese open-weight models on their own infrastructure. If the exemption holds, they are untouched. If the final catalogue narrows it, hosting and fine-tuning could depend on a Beijing license.

The official reasoning

A ministry spokesperson, per The Next Web, said the plan is meant to "prevent misuse and abuse" and "ensure that AI remains under human control". The ministry said it does not target any country or firm. The shape will be familiar from Washington's own chip export controls: licensing, registration and a technology list.

Why it matters for the race

The commercial picture is already lopsided. As we reported, Epoch AI's analysis puts Chinese AI company revenue at about a tenth of US labs, covered in how Chinese AI companies make money. Restricting exports of top models could reduce even that overseas revenue, and it adds a second front in a contest that has been mostly about US limits on China. Separately, our reporting on the Claude API grey market in China shows the other side of the same ledger: access flows across borders despite controls.

Meta's new open-weight model offers a benchmark for the stakes. The rundown we opened, citing Meta's own post, says Muse Spark Open scored 39 on Artificial Analysis' Intelligence Index, behind China's GLM 5.3 at 45, Kimi K3 at 44 and Qwen3.8 at 40. If the leading open-weight models are Chinese, restrictions on them matter far beyond China.

Reading the notice itself

A caution on sourcing. The official notice is in Chinese, and our read of it comes through a summary of its text. The summary confirms the date, the issuing ministries, the 40-technology scope, the open-source carve-out, the comment deadline and the interim registration rule. It does not confirm the parameter threshold or the full list of AI items, which come from press coverage. Until a line-by-line translation is available, those details should be treated as reported rather than established.

What exporters and buyers should do

For Chinese labs, the immediate task is registration and a close read of whether their flagship models fall inside the catalogue. For foreign companies that license or host Chinese models, the task is to ask suppliers whether a covered model is being delivered and under what registration. For policymakers watching the comment window, the question is how the final text treats open-weight releases, since that exemption determines whether the rule touches the models most used abroad.

The window is short: comments opened October 16 and close November 15, 2026, about thirty days.

Our take

This is a draft that already binds, which is unusual. The interim registration rule means exporters face friction now, while the final scope is argued out until mid-November. We would watch the open-source exemption above everything. It decides whether this is a compliance cost for a few firms or a break in the open-weight supply chain that Western developers rely on. Do not trust any headline that says China has "banned" AI exports. The notice does not say that.