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China's First Frontier AI Export Controls: Mofcom Announcement No. 48
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- DeepHorus
China’s Ministry of Commerce and Ministry of Science and Technology issued Announcement No. 48 on October 16, 2026, proposing export controls on frontier artificial intelligence. The draft adds 40 technologies to China’s export catalogue, including 23 AI items. An interim pre-export registration requirement is already in effect, while comments on the catalogue close on November 15, 2026.
The draft covers model weights, checkpoints, source code, architectures, and optimization know-how. A model is restricted if it meets any of three tests: 10^26 FLOPs of training compute, 2 trillion parameters, or a global top-10 ranking. This marks China’s first controls reaching frontier model weights rather than recommendation algorithms.
Agent technologies are controlled separately. Planning, multi-agent coordination, tool use, and game-theoretic decision systems are restricted above set benchmarks. High-performance agents for critical infrastructure, defense, or core government use are prohibited outright.
MOFCOM says API, app, web, SaaS, and lightweight on-device access do not count as exporting a large model. Local deployment of a restricted model abroad does, though automatic licensing may apply on a Chinese company’s own overseas cloud. Licensing deals, ownership transfers, and foreign control shifts can also trigger registration.
The package proposes 14 prohibited and 26 restricted items: 23 in AI, 5 in biomedicine, and 12 in photovoltaics. Prohibited items cannot be exported, while restricted ones need licenses administered by provincial authorities. A MOFCOM spokesperson called the revision routine and said it “does not target any specific country, region, or entity.”
Analysts warn the registration form may capture intra-group code sharing, widening enterprise exposure. The interim rule applies now, including to exports begun but not completed. Companies with cross-border AI development, licensing, or cloud operations face immediate compliance duties as the final catalogue takes shape.
