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Ministry of Commerce Responds to Proposed Addition of AI and Other Technologies to China's Catalogue of Technologies ...

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On October 16, the Ministry of Commerce and the Ministry of Science and Technology issued Announcement No. 48 of 2026, soliciting public comments on the revision of the Catalogue of Technologies Prohibited or Restricted from Export from China, and imposing temporary administrative measures requiring pre-export registration for relevant technologies. A spokesperson for the Ministry of Commerce recently answered reporters' questions on related issues. The announcement stated that this revision is a regular part of technology trade management, conducted in accordance with laws and regulations, and is not targeted at any specific country, region, or entity. The policy objective is to ensure security and controllability while encouraging open source, openness, cooperation, and sharing.

Since 2001, the Ministry of Commerce, together with the Ministry of Science and Technology, has adjusted and revised the Catalogue many times, with items added and removed and with both controls and liberalization, forming a working practice. In recent years, the application of AI, biomedicine, and photovoltaic-related technologies in sensitive fields has continued to expand, and major economies have implemented export controls of varying degrees. China refers to common international practices and implements necessary management in accordance with the law, both to prevent risks of technology loss of control and improper proliferation, and to safeguard normal international technological exchange and cooperation, promoting science and technology for good, security and controllability, and the benefit of humanity.

This public consultation involves the proposed addition of 40 key technologies in three fields: artificial intelligence, biomedicine, and photovoltaics, of which 14 are proposed to be prohibited from export and 26 are proposed to be restricted from export. The prohibited category includes AI-driven malicious code generation and mutation technology, cell and gene therapy technology process platforms with independent intellectual property rights, and perovskite and tandem battery module production technology, among others. The restricted category includes AI-assisted vulnerability discovery technology, novel target discovery and validation technology for universal cell and gene therapy, and polysilicon engineering technology with single-line production capacity of β‰₯30,000 tons/year, among others. The announcement also clarifies circumstances in which facilitation measures apply.

In the field of artificial intelligence, it is proposed to add 23 key technologies related to large models, agents, computing power clusters, and information processing. The Ministry of Commerce stated that the main consideration is to ensure the security and controllability of AI technology. Related technologies such as autonomously driven malicious code generation and mutation can be used to attack sensitive systems such as national critical information infrastructure, national defense and military industry, and core government affairs, or to bypass national security defense systems. If acquired by non-state actors or malicious entities, they may harm national security and the common security of humanity; therefore, it is necessary to strengthen the security baseline and advance international AI governance.

To encourage open source, openness, cooperation, and sharing, for export circumstances such as open-sourcing AI-related technologies, Chinese enterprises building and operating their own computing power centers overseas, going abroad to conduct chip tape-out manufacturing, using overseas resources for joint research and development, and participating in international standard setting, facilitation measures such as automatic licensing apply, basically achieving 'report and export immediately.' Relevant technologies that have already entered the public domain through open source, publication of academic papers, and other means are proposed not to be included in the scope of export management. For technology exports needed by members of the World Artificial Intelligence Cooperation Organization for international cooperation on capacity building, technology sharing, and joint rule-making, more facilitation and support will be provided.

In biomedicine, it is proposed to add 5 technologies related to pathogenic microorganisms, cell and gene therapy, and small nucleic acid drugs. Pathogenic microorganism technology and others directly relate to human health and national biosecurity, and are proposed to be prohibited from export; external licensing of related technology process platforms, outsourced research and development and production services, etc., will not be included in management, and external licensing of target discovery and validation technology will apply automatic licensing. In photovoltaics, it is proposed to add 12 technologies in links such as polysilicon manufacturing, wafer manufacturing, and cell manufacturing, because photovoltaics are expanding their applications in sensitive fields such as aerospace, national defense, unmanned equipment, and high-security-level infrastructure.

The announcement also establishes temporary pre-export registration management. From the date of issuance of the announcement until the date the formal revision announcement of the Catalogue takes effect, technology export operators, before exporting technologies listed in the announcement, shall register in the Technology Trade Management Information Application on the Ministry of Commerce's unified business system platform. Circumstances requiring registration include transferring technology ownership to overseas parties, licensing domestic technology for use overseas, changes in the domestic technology owner or actual controller to an overseas entity, and other circumstances explicitly required by the Ministry of Commerce to be registered. Exports of key and core photovoltaic equipment all require registration.

A spokesperson for the Ministry of Commerce stated that the scope of this listing is precise and limited, most technologies have clear specific indicators, and products manufactured using the relevant technologies are not within the scope of management. The policy will be dynamically adjusted in accordance with the law, and non-advanced or backward technologies will be removed from the Catalogue in a timely manner. Regarding large models 'going overseas,' overseas localized deployment falls within the scope of technology export management; deployment in overseas self-owned clouds and other circumstances where risks are relatively controllable may apply automatic licensing; API calls, APP/webpage interactions, SaaS applications, and local on-device lightweight deployment do not fall within the scope of large model technology export management. The vast majority of AI technologies can still be exported freely.