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Export Control List Amendment Covering AI Technologies (Draft for Comment)

人工智能相关技术出口限制清单(征求意见)
商务部·Published 2026-10-16·Checked by 管理员 on 2026-10-17

China's Ministry of Commerce has published a draft for public comment proposing to add AI-related technologies — including large models, AI agents, and computing clusters — to the export restriction list. The item is still in the consultation stage; the exact scope and effective date will be set in follow-up MOFCOM documents. It marks China's first discussion of subjecting AI models themselves to export controls.

What it means for you

  • Export of large models, AI agents and computing cluster technologies would become restricted, so cross-border licensing, partnerships and deployments need export-control review
  • The list is open for comment; companies can submit feedback to MOFCOM to shape the final scope
  • Firms relying on Chinese model technology for overseas operations must prepare export compliance workflows and licensing procedures
  • What to do

    LegalAssess whether existing cross-border transfers of model, agent and compute technologies fall within the proposed restricted list
    ComplianceSubmit comments to MOFCOM during the consultation, focusing on how the proposed scope affects the business
    ComplianceEstablish or update AI export compliance workflows, including licence application and transaction screening
    LegalReview overseas partnership and deployment contracts involving Chinese model technology and add export-control clauses

    Key dates

    2026-10-16Published

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