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Addition of 23 AI Technologies to China's Export Prohibition and Restriction Catalogue (Joint Announcement No. 48)

《中国禁止出口限制出口技术目录》增列23项AI技术（第48号联合公告）

商务部、科技部·Published 2026-10-17·Checked by 管理员 on 2026-10-19

China's Ministry of Commerce and Ministry of Science and Technology issued Joint Announcement No. 48, proposing to add 23 AI technologies — including large models, agents, and computing cluster technology — to the Catalogue of Technologies Prohibited or Restricted from Export, alongside biopharma and solar technologies. Interim export registration applies immediately during the consultation period, requiring disclosure of the recipient, purpose, and amount. Technologies already in the public domain via open source or publications are exempt, while transfers of control to foreign entities or deployment of tech stacks on overseas servers trigger registration.

Source ↗Remind me China · All

What it means for you

Exporting non-public large model, agent, or computing cluster technologies via licensing, sale, or weight delivery requires interim registration with MOFCOM during the transition; in-flight transactions are also covered, with no grandfathering.

Technologies genuinely released via open source or publications are exempt, but partially open-sourced items (e.g., released weights with unpublished training methods or data engineering) remain restricted, creating a "publish first, export later" window until the catalogue takes effect.

Foreign acquisition, red-chip restructuring, or deploying tech stacks on overseas servers is deemed a technology export, requiring restructuring of agent-service overseas expansion plans.

What to do

LegalInventory ongoing and planned cross-border licensing, delivery, and in-flight transactions involving large model, agent, and computing cluster technologies to confirm whether interim registration is triggered

ProductEvaluate models planned for open-sourcing and complete genuine public release before the catalogue takes effect to obtain the public-domain exemption

ComplianceReview shareholding structure and overseas deployment architecture (red-chip, overseas servers) for control-change and foreign-use triggering risks

LegalPrepare registration documentation templates covering recipient, purpose, and amount reporting workflows

EveryoneTrack the consultation deadline and submit industry comments