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China proposes export controls on frontier AI models

China proposes export controls on frontier AI models

Rule Changes

MOFCOM Announcement No. 48 would add 23 AI technologies to the export control list, with registration already in effect.

Overview

Updated 1 hour ago

China's Ministry of Commerce proposed adding 23 artificial intelligence technologies to its export control catalogue on October 16. The draft covers model weights, AI agents, chip design, and the networking software for large computing clusters. Registration for exports of the listed technology began the same day, before the list is final.

The draft leaves most AI business untouched. Foreign customers can still use Chinese models through apps, websites, and cloud APIs. But moving the underlying technology abroad, or selling a Chinese AI company to a foreign owner, now requires notifying Beijing first.

Why it matters

Chinese AI labs can still sell access to their models abroad, but the weights and know-how behind them now need Beijing's permission to leave.

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Key Indicators

23
AI technologies proposed for export control
Part of 40 technologies across AI, biopharma, and solar in Announcement No. 48.
40
Total technologies proposed for the catalogue
The package also covers biopharma and solar manufacturing.
2 trillion
Parameter threshold for covered models
A model of this size or larger is presumed to need export registration.
10²⁶
Training compute threshold (FLOPs)
Models trained with this much computing power fall under the draft.
November 15
Public comment deadline
MOFCOM is taking comments on the draft until mid-November 2026.
29
Founding governments of WAICO
The China-initiated AI body established in July 2026.

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People Involved

Organizations Involved

Timeline

April 2026 November 2026

4 events Latest: October 16th, 2026 · 2 weeks ago
Tap a bar to jump to that date
  1. Public comment period closes

    Upcoming Deadline

    MOFCOM's comment window on the draft is scheduled to end.

  2. MOFCOM proposes 23 AI export controls

    Latest Rule change

    Announcement No. 48 adds AI, biopharma, and solar technologies to the draft catalogue. Registration starts immediately.

  3. China launches WAICO with 29 founding governments

    Institution

    The new body is meant to coordinate AI cooperation among member states.

  4. China blocks Meta's acquisition of Manus

    Regulatory

    The foreign-investment security review office orders Meta to unwind the deal.

Scenarios

1

MOFCOM finalizes the AI export list before 2027

Likely Resolves by End of 2026

Discussed by: Reuters, citing a source familiar with the discussions

Reuters reported that China is expected to adopt the proposals by the end of the year and issue implementation guidelines later. If that happens, the 23 AI technologies move from a draft with temporary registration to a permanent licensing regime.

2

Comment period narrows the AI thresholds

Possible Resolves by Q1 2027

Discussed by: Liu Jing of Beijing Dacheng Law Offices, and analyses by Han Kun and Fangda

Companies and law firms have asked how MOFCOM will count model size for systems that activate only part of their parameters, and which rankings count for the top-10 test. The final text could raise thresholds or add definitions.

3

Registration blocks a Manus-style AI transfer

Possible Resolves by Q2 2027

Discussed by: The Diplomat

The registration requirement lets MOFCOM see a transfer of listed AI technology before it closes. A company that tries to move model weights or an AI business to a foreign owner could be ordered to stop, as Meta was ordered to unwind Manus.

Historical Context

3 moments from history that rhyme with this story — and how they unfolded.

October 2022

US AI chip export controls (2022)

The U.S. Commerce Department restricted exports of advanced AI chips and chipmaking equipment to China. Nvidia's most advanced processors could no longer be sold there without a license.

Then

Nvidia designed slower chips for the Chinese market, and the controls were expanded in 2023 and 2024.

Now

The rules pushed China to build domestic chip capacity and to look for ways to train models abroad.

Why this matters now

China's draft is a mirror move at the model layer, after the U.S. restricted the hardware layer.

July 2023

China's gallium and germanium export controls (2023)

China announced that exports of gallium and germanium, two metals used in semiconductors, would require licenses. The controls took effect in August 2023.

Then

Prices rose and buyers scrambled for alternatives.

Now

The move showed Beijing would use export controls as counter-leverage in the chip dispute.

Why this matters now

The AI draft follows the same playbook: register exports before they happen, then decide which ones to allow.

2010-2014

China's rare earth export restrictions and the WTO case (2010-2014)

China cut rare earth exports to Japan during a territorial dispute. The U.S., European Union, and Japan filed a complaint at the World Trade Organization.

Then

The WTO ruled in 2014 that China's quotas violated its commitments.

Now

China replaced quotas with a licensing system that still lets it track and restrict exports.

Why this matters now

The episode shows export controls can invite legal challenge, and that China has since preferred licensing and registration over outright quotas.

Sources

(10)