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On October 16, the Ministry of Commerce and the Ministry of Science and Technology issued Announcement No. 48 of 2026, proposing revisions to the Catalogue of Technologies Prohibited or Restricted from Export in China, seeking public comment, and simultaneously implementing pre-export registration management for relevant technologies.
The public consultation covers 40 technologies across three fields: artificial intelligence, biomedicine, and photovoltaics. Among them, the artificial intelligence field includes 23 technologies related to large models, agents, computing clusters, and information processing.
The catalogue is still under public consultation, while registration has already begun
The announcement specifies that the public may submit comments from October 16 to November 15 on the scope of newly added technologies, indicators, control policies, and facilitation measures.
At the same time, from the date of the announcement until the date the catalogue is officially revised and implemented, operators must register through the relevant business system of the Ministry of Commerce before exporting the technologies listed in the annex. Exports that have begun but not yet been completed are also within the scope of registration.
Therefore, the proposed revised catalogue is still pending subsequent procedures, but the interim registration arrangement has already been launched. The two should not be conflated to mean that all proposed restrictions have been formally implemented.
Focus on specific forms of technology transfer and licensing
The registration scenarios listed in the announcement include transferring technology ownership to overseas parties, authorizing overseas use of domestic technology, and changes in the owner or actual controller of domestic technology to an overseas entity.
For technologies that have entered the public domain through open source, publication of academic papers, and other means, the announcement explicitly excludes them from the scope of management. Whether a specific project involves the technologies in the annex and related conditions still needs to be determined based on complete materials.
International cooperation enters a more detailed discussion of technical boundaries
AIYXL Observation: What is noteworthy about this announcement is that the technical objects, rights arrangements, and transaction forms in AI international cooperation will be subject to more specific scrutiny.
For industry observers, follow-up should continue to track the consultation results, the formal catalogue, and accompanying explanations, distinguish different scenarios of technology export, product sales, and service provision, and avoid summarizing this policy change as a "comprehensive ban on model exports."
Source: https://www.mofcom.gov.cn/