ChinaLawConsultationModel providersChina outbound

Revision of the Catalogue of Technologies Prohibited or Restricted from Export (AI technologies)

《中国禁止出口限制出口技术目录》修订(人工智能技术增列)
商务部、科技部·Published 2025-10-16·Checked by 管理员 on 2026-10-27

On 16 October, MOFCOM and MOST opened public consultation on revising China's Catalogue of Technologies Prohibited or Restricted from Export, adding 23 AI technologies covering large models, agents, compute clusters and information processing. MOFCOM clarified that open-sourced or publicly published technologies fall outside export controls; overseas localised deployment of restricted models qualifies for automatic licence facilitation; and API calls, SaaS and lightweight on-device deployment are outside scope. DeepSeek and MiniMax have completed registration procedures.

What it means for you

  • Overseas localised deployment or licensing of restricted AI technologies (large models, agents, compute clusters, 23 items) requires export registration/licensing, with automatic licences processed essentially on submission.
  • Open-sourced or published technologies are exempt; API calls, SaaS and lightweight on-device deployment are outside export control scope.
  • Building overseas compute centres, offshore chip tape-outs and international joint R&D qualify for automatic licence facilitation.
  • What to do

    LegalMap the company's overseas AI business models against the restricted technology list to determine export control scope
    ComplianceIf overseas deployment or technology licensing is involved, complete registration/automatic licence procedures with MOFCOM
    EveryoneTrack the final catalogue text and assess impact of the 23 technology items on products and licensing strategy
    ProductLeverage open-source exemptions and automatic licence facilitation when planning overseas deployment and open-source releases

    Key dates

    2025-10-16Published

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