China proposes export controls on 23 AI technologies, testing fragile trade truce

China's Ministry of Commerce and Ministry of Science and Technology on Friday published a draft revision of the country's catalogue of technologies barred or restricted from export, proposing to add 40 items spanning artificial intelligence, biomedicine and solar-power manufacturing. The draft, released as Announcement No. 48 of 2026, is open for public comment through Nov. 15, and an interim registration requirement for the newly listed technologies took effect immediately, covering deals already underway.

The move is the most significant update to China's export-control architecture for the technology sector since 2023, and it lands at a delicate moment: a tariff truce between Washington and Beijing, extended last month to Jan. 10, is already under strain, and both governments have spent the year tightening, rather than loosening, the rules governing cross-border transfers of advanced computing and model technology.

The timing is not incidental. Treasury Secretary Scott Bessent announced on Sept. 23 that Washington and Beijing had extended their tariff truce, first struck in Busan last October, by two months to Jan. 10, 2027 — shorter than the six-month extension many analysts had expected, and one Beijing has not formally confirmed. China's exports, meanwhile, have kept climbing: customs data released Oct. 14 showed September exports rose 36.3 percent from a year earlier, with semiconductors and automated data-processing equipment among the biggest contributors.

A wider net on artificial intelligence

Of the 40 proposed additions, 23 relate to artificial intelligence, covering large language models, autonomous agents, computing clusters and information-processing systems, according to the draft list of covered technologies that the two ministries attached to the announcement. Five items concern biomedicine, chiefly cell and gene therapies and small nucleic-acid drugs, and twelve cover photovoltaic manufacturing, including polysilicon, wafer and solar-cell production equipment.

Reporting on the draft's technical annex, which has circulated among trade lawyers and semiconductor analysts, describes the AI threshold as catching frontier systems above roughly two trillion parameters or those ranking among the world's ten most capable models by performance or usage, along with any model trained on what China's Data Security Law defines as "core data." Model weights, checkpoints, source code and architecture details would all count as controlled technology once a model crosses that line.

In a question-and-answer release accompanying the draft, a ministry spokesperson said the additions are meant to keep artificial intelligence "safe and controllable" and to prevent its misuse by non-state or malicious actors against critical infrastructure, defense systems and government networks. The spokesperson said the changes are routine and not aimed at any particular country, and emphasized that technology already disclosed through open-source releases or academic papers would remain outside the controls, with streamlined, largely automatic licensing for open-source exports. Access to restricted models through APIs, apps or software-as-a-service offerings would not count as a technology export at all; only local deployment of the underlying model abroad would trigger the rule.

Chinese state media framed Friday's announcement as consistent with that pattern of assertiveness rather than retreat, with Global Times describing the revision as a defense of China's technological and economic interests and a practice that mirrors existing export-control regimes in the United States, the European Union, Japan and South Korea.

Who the draft would touch

The clearest effect would fall on Chinese AI developers that have spent the past year pushing their models into overseas markets. Companies such as Alibaba, Moonshot AI and Zhipu's Z.ai have licensed open-weight models abroad or made them available through foreign cloud platforms, including Amazon Web Services, partly to compete with American labs on price and partly to build international developer ecosystems. A formal licensing requirement for any model that crosses the draft's size or capability thresholds would add a bureaucratic step — and, for some transactions, a potential veto — to deals that previously moved without government sign-off.

The reach extends beyond AI narrowly defined. Trade lawyers flagged that the interim registration rule covers not just outright technology transfers but also overseas licensing arrangements, and any transaction that would shift ownership or control of a Chinese-held technology to a foreign party — a definition broad enough to sweep in cross-border acquisitions and joint ventures in biopharmaceuticals, and potentially some semiconductor supply arrangements involving offshore chip fabrication of Chinese-designed products.

Analysts cautioned against reading the draft as a blanket ban. The National reported that Leonhard Xu, a senior consultant at the Berlin-based consultancy Sinolytics, called the announcement "extremely expansive" and said it would take time to fully assess its implications, while noting that export controls of this kind typically function as licensing regimes rather than outright prohibitions. Ting Peng, a trade-compliance partner at Shenzhen's BZW Law Firm, said companies involved in cross-border acquisitions, intellectual-property restructuring or international licensing arrangements should review whether their deals fall under the new registration rules, adding that the biopharmaceutical sector is particularly exposed.

Reaction in Washington

The sharpest reaction came from trade-policy watchers in the United States, where the draft is being read as a signal that Beijing intends to use its own export-control machinery as actively as Washington has used export controls on advanced chips and chipmaking equipment sold to China. Wendy Cutler, vice president of the Asia Society Policy Institute and a former acting deputy U.S. trade representative, said the announcement underscores how tenuous the current detente remains.

"The fragility of our trade truce cannot be overstated," said Wendy Cutler, vice president of the Asia Society Policy Institute. "Beijing is going full steam ahead in efforts to control exports of strategic goods to the US and others."

Cutler added that she expects it will "only be a matter of time" before Washington responds with its own restrictions, a dynamic that has repeated through much of the past two years of tit-for-tat controls on chips, rare earths and now, potentially, AI software itself.

What happens next

For now, nothing in the draft is final. The two ministries are soliciting written comments — by email, fax or post — through Nov. 15, after which they are expected to issue a revised catalogue with a firm effective date. Trade lawyers said the interim registration requirement, which applies even to exports that have already begun shipping, gives companies little room to wait out the comment period before adjusting their compliance procedures.

The biggest open question, according to analysts tracking China's AI sector, is how the final rule will treat open-weight models — the licensing approach that has allowed Chinese developers such as Moonshot and Alibaba to compete internationally even as Washington tightened chip exports. How Beijing resolves that tension, and whether the United States responds with new restrictions of its own, will likely shape the next phase of a technology rivalry that neither government shows signs of de-escalating.