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The Ministry of Commerce and Ministry of Science and Technology published Announcement No. 48 on October 16, 2026. The consultation runs through November 15, 2026, so the catalogue is not yet final and its technical thresholds and implementation practice can still change.
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What China announced on October 16
Announcement No. 48 starts a public consultation on revisions to China’s catalogue of technologies prohibited or restricted from export. It also introduces interim registration for covered transfers from the announcement date until the revised catalogue formally takes effect.
The registration requirement is significant because companies may have compliance work to do before the final list is published. The notice covers transfers of ownership, overseas licensing, and changes in ownership or control to an overseas entity. A filing is expected to identify the exporter and recipient, destination, intended use and expected transaction value.
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Which technologies are covered
Artificial intelligence
AI accounts for 23 of the 40 technologies in the draft. The categories described by the ministries include large models, AI agents, computing clusters and information-processing technologies. The list also cites capabilities such as malicious-code generation and mutation and AI-assisted discovery of software vulnerabilities.
Biomedicine, photovoltaics and chips
The draft also addresses cell and gene therapy, polysilicon engineering and battery technologies. The Associated Press described the proposal as spanning AI, chips, solar power and biomedicine. The ministries’ summary emphasizes AI, biomedicine and photovoltaics as the headline sectors, with chip-related technology discussed in the broader account of the proposal.
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| Proposed treatment | Number of technologies | Practical effect |
|---|---|---|
| Prohibited | 14 | Exports of listed technologies would not be permitted under the proposed catalogue. |
| Restricted | 26 | Transfers would require the applicable export licence or other approval process. |
The examples above illustrate the subjects named in the announcement materials; they do not establish that every example falls into the same treatment category. The final catalogue will determine the exact technical descriptions, thresholds and classification of each item.
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No blanket ban has been announced. The proposal distinguishes between transferring restricted large-model technology for local deployment abroad and providing access to a model as a service.
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Overseas local deployment can be covered
The ministry’s explanation says overseas local deployment of restricted large-model technology is within scope. A transfer of model technology or related rights that lets an overseas entity run the technology on its own infrastructure therefore needs careful classification and may require registration and a licence under the final rules.
Remote access is generally treated differently
The same explanation says API calls, app or web interaction, software-as-a-service access and lightweight on-device deployment generally are not treated as exporting the large-model technology. “Generally” matters: the final catalogue, the technical facts of a transaction and later implementation guidance could affect the result.
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What companies transferring Chinese technology should do now
- Map the technical content. Determine whether the transaction involves model weights, training or inference systems, an AI agent, computing-cluster technology, information-processing technology, biomedical know-how, photovoltaic processes, batteries or another listed category.
- Classify the delivery model. Separate an ownership transfer or overseas licence from hosted API access, a web application, SaaS, or a lightweight device implementation. Do not assume that a product label alone determines the legal treatment.
- Identify every party and destination. Record the exporter, recipient, end use, destination and any proposed change in ownership or control involving an overseas entity.
- Prepare interim registration information. The notice calls for exporter and recipient identities, destination, intended use and expected transaction value. Covered transfers should be assessed from October 16, 2026, even though the revised catalogue is still under consultation.
- Check the final catalogue and licensing route. The consultation closes November 15, but the effective date of the revised catalogue has not been stated. Technical thresholds and procedures may change before adoption.
Open-source technology and cooperation channels
The proposal is not designed to eliminate every form of international collaboration. Publicly available technology released through open-source channels or academic publication is proposed to fall outside the catalogue’s administration.
The official materials also describe facilitation for specified overseas computing, chip-fabrication, joint-research and standards activities through automatic-licensing arrangements. That language refers to defined activities and does not mean every research or commercial transaction receives automatic approval; companies will need to verify whether a project meets the eventual conditions.
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Why Beijing says it is acting
The Commerce Ministry says the controls are intended to reinforce a security baseline, prevent misuse and uncontrolled diffusion, and ensure that AI remains under human control. Its official Q&A describes the revision as legally grounded and says it is not aimed at a particular country, region or entity.
The Associated Press placed the announcement in the context of intensified technology competition with the United States. That is geopolitical context rather than a statement that the catalogue targets the United States: the ministry’s stated position is that the revision is generally applicable.
What remains unsettled
- The catalogue is a consultation draft, not a final rule.
- The final technical definitions and thresholds for the 40 technologies have not been established in the material released so far.
- The effective date of the revised catalogue is not specified.
- Licensing and registration practice may determine how borderline cases, mixed technology transfers and changes in corporate control are handled.
- The distinction between local overseas deployment and remote service access will depend on the final wording and the facts of each arrangement.
How the proposal affects common transactions
Licensing model technology to an overseas subsidiary
A transfer of restricted model technology for the subsidiary’s local deployment is the type of transaction that should be screened for interim registration and a future export licence.
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Under the ministry’s explanation, API access is generally not treated as exporting the large-model technology. The provider should still document what is delivered and monitor the final rules rather than relying solely on the service label.
Working with an overseas research or standards group
A qualifying joint-research or standards activity may benefit from the proposed automatic-licensing facilitation. Eligibility and conditions remain subject to the final catalogue and implementing procedures.
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