What happened
On 16 October, China's Ministry of Commerce and Ministry of Science and Technology jointly published a draft revision of the Catalogue of Technologies Prohibited and Restricted from Export. The draft would add 40 technologies across three fields: 23 in artificial intelligence, five in biomedicine and 12 in solar manufacturing. According to TechNode Global's summary of the announcement, 14 of the 40 would be prohibited from export and 26 restricted.
The AI items cover large models, AI agents, computing clusters and information-processing technologies. Among the proposed prohibitions are systems that generate or modify malicious code on their own, and certain core large-model technologies trained on sensitive national data. The Associated Press, as cited by TechNode, reported that models with at least two trillion parameters, or with specified globally leading capabilities, could fall into the restricted category.
Registration applies before the rules are final
The catalogue is still a draft, and comments are open until 15 November. Even so, the ministries brought in a temporary pre-export registration duty from the date of the notice. Exporters must register through the commerce ministry's technology-trade platform before they transfer ownership of listed technology abroad, license it to foreign users, or let a foreign entity become the owner or controller of the technology. Deals that have started but not yet completed are also caught. The filing asks for details of both parties, the destination, the intended use and the expected value of the export.
What is left out
The ministry said technology already in the public domain through open-source releases or academic papers is outside the scope. It also said that overseas use through APIs, websites, apps or software-as-a-service would generally not count as an export of large-model technology, provided no restricted technology is transferred. Simplified or automatic licensing may be available for Chinese firms running their own cloud or computing centres abroad.
Why it matters financially
For Chinese AI developers, licensing deals, overseas model deployments and foreign investment that changes who controls a technology now carry a new reporting step, and could later need a licence or be blocked outright. Because the scope reaches across AI, chip design and solar manufacturing (polysilicon, wafers and cells), it could affect the value of cross-border joint ventures and acquisitions. The final thresholds may still change after the consultation.