China proposes export controls for 23 AI technologies

China’s Ministry of Commerce and Ministry of Science and Technology opened public consultation on October 16 on proposed export controls covering 23 artificial intelligence technologies. The announcement also placed relevant technology transfers under a temporary pre-export registration regime with immediate effect.

The additions to China’s catalog of technologies prohibited or restricted from export are not final. Comments are open through November 15, and the interim registration requirement is due to remain in place until a revised catalog is formally issued and implemented. The temporary requirement also covers exports that have begun but are not yet complete.

The full proposal covers 40 technologies across three sectors: 23 related to AI, five to biomedicine and 12 to photovoltaics. The Commerce Ministry said 14 of the 40 would be prohibited from export and 26 would be restricted. That split applies to the complete cross-sector list, not only the AI technologies.

The AI portion includes technologies involving large models, AI agents, computing clusters and information processing. AI technology already put into the public domain through an open-source release or academic publication is excluded from the proposed scope. Products made with covered technology are generally outside the proposed technology-control regime. According to the ministry’s explanation, the proposal sets technical thresholds for most of the technologies.

Under the temporary regime, registration is required before transfers that send technology ownership abroad, license Chinese technology for use abroad or place a domestic technology owner or its actual controller under a foreign entity. Registrants must principally disclose the exporter and recipient, destination, technology and intended use, and expected export value. The registration process does not make the proposed catalog additions final.

For the planned final regime, the ministry said locally deploying a large model overseas when it contains restricted technology would fall under technology-export management. External access through an API, app or website, use through software as a service, and lightweight deployment on a device would not be treated as exports of large-model technology. The ministries have not said when a final revised catalog will be issued after the comment period closes.