China proposes export controls on 40 technologies, starts interim registration ahead of amendment
Key Facts
China's commerce and science and technology ministries published a draft on 16 October 2026 to add 40 technologies to the list of technologies prohibited or restricted from export, alongside the introduction of interim pre-export registration. The additions cover artificial intelligence, biomedicine and solar energy, according to the Commerce Ministry's official announcement. The government proposes banning exports of 14 technologies and restricting another 26, according to an explanation by the ministry's spokesperson. Under China's system, prohibited technologies cannot be exported, while restricted technologies require an export licence. The ministry said its objective in AI was to "prevent misuse and malicious use, and ensure that AI always remains under human control".
AI accounts for 23 of the proposed technology additions, covering large models, intelligent agents, computing clusters and information processing. Examples of technologies proposed for an export ban include AI-powered generation and modification of malicious code, according to the Commerce Ministry's explanation. AI-assisted vulnerability detection is among the examples of technologies proposed for export restrictions. The draft exempts technologies made publicly available through open-source releases or publication in academic papers. Beijing stressed that the amendment "does not target any particular country, region or entity".
The interim registration requirement extends to exports of listed technologies that have already begun but remain incomplete, according to the official announcement. Transactions subject to registration include transferring technology ownership overseas, including the assignment of intellectual property rights. They also include licensing an entity outside China to use technology located within the country, such as licensing the use of intellectual property rights. Transfers of ownership or effective control of technology located in China to a foreign entity are also subject to registration. Registration must include basic information about the exporter and recipient, the destination country or region, the technology to be exported and its uses, as well as the expected value of the export transaction.
Once the list amendment takes effect, on-premises deployment overseas of AI technologies classified as restricted will be subject to technology export controls, according to the Commerce Ministry. Deployment through a company's own cloud overseas may qualify for automatic licensing, as a case involving relatively manageable risks. The ministry proposes similar streamlined technology export procedures for open-source releases of AI technologies and for Chinese companies establishing computing centres they own and operate abroad. The streamlined procedures cover overseas chip manufacturing, joint research using external resources and participation in setting international standards. The ministry, meanwhile, excludes the provision of large-model services through application programming interfaces or interaction through apps and web pages from the scope of model technology exports. The exemption also applies to software as a service and lightweight deployment on local edge devices.
In solar energy, the draft proposes listing 12 technologies related to the manufacture of polysilicon, silicon wafers and cells, according to the official announcement. The scope of technology controls extends to key and core equipment incorporating the covered technologies. Examples of proposed bans include technologies for producing perovskite and tandem solar cell modules, according to the ministry's explanation. Biomedicine accounts for 5 technologies related to cell and gene therapy, small nucleic acid drugs and pathogenic microorganisms, with proposed bans including proprietary process platforms for cell and gene therapy. The ministry clarified that products manufactured using technologies proposed for inclusion do not themselves fall within the scope of controls on those technologies.
China's list dates back to 2001, when the Commerce Ministry issued it jointly with the Ministry of Science and Technology. Parts of it were amended in 2008, 2020 and 2023, according to the history presented by the ministry. In the July 2025 amendment, China removed 3 technology entries, added 1 and amended 1. This included placing technologies for manufacturing battery cathode materials in the restricted category, including lithium iron phosphate and lithium manganese iron phosphate. Technologies outside the list fall into the freely exportable category and are subject to contract registration, according to the ministry's explanation of the technology export system.
Leonhard Schu, a consultant at Sinolytics, described the announcement as "extremely far-reaching", in comments reported by The National on the day of the announcement. He added that "assessing its full implications will take time". The commerce and science and technology ministries pledged to review the scope of the list on an ongoing basis in line with technological developments. This mechanism includes removing technologies that lose their technological edge or become obsolete, according to the Commerce Ministry's explanation. The draft remains open for public consultation until 15 November 2026, the deadline for comments.