China’s Proposed AI Export Controls: What Changes

The United States restricted China’s access to advanced computing chips. China’s October 2026 proposal draws a different boundary: transferring selected AI technologies abroad would be controlled separately from providing access to AI services.

On October 16, China’s commerce and science ministries published proposed additions to its catalogue of technologies prohibited or restricted from export. The consultation covers 40 technologies, including 23 involving AI models, agents, computing clusters and information processing. Public comments remain open until November 15.

The final restrictions have not been adopted. However, a temporary registration requirement took effect immediately. It covers exports of listed technologies through ownership transfers, overseas licensing and changes that place ownership or actual control with foreign entities. Transactions underway but unfinished are covered.

That distinction matters: this is about transferring technology, with separate treatment for providing services.

China’s commerce ministry says overseas access through APIs, apps, websites and software services would fall outside the proposed controls on large-model technology exports. Overseas deployment involving restricted technology would be covered, although deployment on a company’s own overseas cloud could qualify for automatic licensing.

The ministry also identifies exemptions for technology already in the public domain through open-source releases or academic publications, alongside simplified arrangements for specified international activities.

The American comparison concerns a different layer. Washington’s October 2022 controls targeted advanced computing chips, supercomputing capabilities and semiconductor manufacturing.

These announcements do not establish two sealed AI markets or demonstrate Chinese technological superiority.

They establish a narrower distinction: international access to an AI service and permission to transfer its underlying technology are separate questions under export controls.

Sources and context

• China’s draft catalogue and interim registration requirements (Primary source)
• MOFCOM explanation of AI technology transfers and service access (Primary source)
• BIS: October 2022 advanced-computing and semiconductor controls (Primary source)