China Proposes Bans on 14 Technologies, Restrictions on 26 in Review Covering AI
Key Facts
China's commerce and science and technology ministries published a draft on October 16 to amend the list of technologies banned or restricted for export, opening it for public consultation. The draft proposes banning exports of 14 technologies and restricting 26 others in a review covering artificial intelligence, biotechnology and solar energy. The Ministry of Commerce said the review is a routine measure for managing technology trade and does not target any specific country, region or entity. The ministry said the proposals aim to manage the risks of technology proliferation and ensure its safe use. The measures remain proposals during the consultation period, while the ministry has introduced temporary advance registration requirements for the technologies covered until the amendment is adopted and takes effect.
The proposed list covers 40 technologies across the three fields, including 23 related to artificial intelligence. This group includes technologies relating to large models, agents, computing clusters and information processing. The ministry says most technologies proposed for inclusion have specific technical indicators, and products manufactured using them do not fall within the scope of the proposed controls. The draft also proposes exempting technologies that have entered the public domain through open-source resources or the publication of academic papers. The ministry said the measures aim in part to "strengthen the safety line, prevent misuse and ensure that artificial intelligence remains under human control."
The draft includes core technologies for large artificial intelligence models trained using sensitive national data, according to the Associated Press. The proposed restrictions may cover models with more than 2 trillion parameters, or models with specified leading capabilities. This means the review's scope is not limited to hardware or computing components, but extends to the technologies used to develop the models themselves. According to the Commerce Ministry's clarification, deploying a restricted model domestically abroad may be subject to technology export controls. Making the model available through APIs, applications, websites or software services is not considered an export of the model technology under the scope set out in the clarification.
During the transition period, exporters of technologies listed in the annex must register them with the Ministry of Commerce before exporting them. This includes transferring ownership of the technology to an entity outside China, such as transferring intellectual property or licensing its use abroad. It also includes changing the owner of the technology or the party that actually controls it to a foreign party. The ministry said, however, that some activities may qualify for automatic licensing, including Chinese companies setting up self-operated computing centers abroad, manufacturing chips there and conducting joint research using external resources. These exemptions show that the draft distinguishes between forms of technology transfer and activities that may qualify for streamlined licensing procedures.
In a clarification published on October 20, the Ministry of Commerce said it had reviewed the scope of the proposals with research and industry institutions and consulted companies, reiterating that the amendment does not target any specific entity. The proposal came as China and the United States made progress in talks on artificial intelligence safety and governance and a mechanism for notifying each other of incidents that could threaten national security, according to the Associated Press. The agency placed the move in the context of U.S.-led restrictions that in recent years have limited China's access to some advanced technologies, the latest AI chips and the equipment used to manufacture them. An analyst at Omdia said the move could be seen as a response to sovereignty requirements put forward by Western countries for artificial intelligence, robotics, communications and other core technologies. An economist at Natixis added that "the world is seeing greater fragmentation in trade and investment, as well as in access to technologies."
The draft coincided with a 4.3% year-on-year decline in actually utilized foreign investment in China to 5488.1 billion yuan in the January-to-September 2026 period, according to Ministry of Commerce data. By contrast, actually utilized investment in high-tech industries rose 33.8% over the same period. These figures provide contemporaneous context for the proposal, but do not establish a causal link between it and investment flows. Public consultation runs through November 15, 2026, the next specified date in the review process. After the comment period ends, the ministry said the list will undergo formal revision before taking effect, without specifying a date for that in the available materials.