China's Ministry of Commerce and the Ministry of Science and Technology jointly announced on October 16 a proposed revision to the Catalogue of…
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China Plans to Add 40 Technologies Including Large Language Models and Photovoltaic Silicon Wafers to Export Controls, Effective Immediately with Interim Registration
2026-10-16 16:26 (GMT+8)
China's Ministry of Commerce and the Ministry of Science and Technology jointly issued an announcement on October 16 soliciting public comments on revisions to the Catalogue of Technologies Prohibited and Restricted from Export in China, proposing to add 40 technologies across three sectors—artificial intelligence, biomedicine, and photovoltaics—to the restricted export list, with interim pre-export registration requirements taking effect immediately upon the announcement's release.
This represents a major expansion of China's technology export control regime. According to the announcement, artificial intelligence accounts for the largest share of the proposed additions, encompassing 23 technologies related to large language models, AI agents, computing clusters, and information processing. The photovoltaic sector covers 12 technologies including polysilicon manufacturing, silicon wafer production, and cell manufacturing. The biomedicine sector includes 5 technologies spanning cell and gene therapy, small nucleic acid drugs, and pathogenic microorganisms.
The announcement clarifies that AI technologies that have already entered the public domain through open-source releases or academic publications are not subject to the controls. In the biomedicine sector, outbound licensing models that do not involve ownership transfers qualify for facilitation measures such as automatic licensing. The photovoltaic technology controls also extend to key and core equipment that embodies the relevant technologies.
A spokesperson for China's Ministry of Commerce stated in a same-day press briefing that the revision was preceded by extensive assessments conducted with research institutions and industry organizations, with full input from major enterprises. The spokesperson said the policy design reflects three characteristics: the scope of controls is precise and limited, with most technologies having clearly defined technical specifications and products manufactured using the relevant technologies falling outside the scope; facilitation measures are available, with multiple export scenarios explicitly eligible for streamlined arrangements; and dynamic adjustment will be implemented, with outdated or non-advanced technologies promptly removed from the catalogue as technology evolves.
Interim Registration System Takes Effect Immediately
Concurrent with the public comment period, pre-export registration management takes effect immediately from the announcement's release date on October 16 and remains in force until the catalogue is formally revised and implemented. This means that during the transition period, technology exporters must complete registration on the Ministry of Commerce's unified business system platform—specifically the technology trade management information application—before exporting technologies listed in the announcement's annex.
The announcement enumerates four categories of export scenarios requiring registration: transferring technology ownership to foreign parties (such as intellectual property transfers); licensing domestic technology for use abroad (such as IP licensing); changes in ownership or actual control of domestic technology to foreign entities; and other scenarios explicitly requiring registration through Ministry of Commerce notifications or similar means. Exports that have already commenced but are not yet completed are also subject to registration.
Registration information includes basic details of the technology exporter and recipient, destination country or region, the technology to be exported and its intended use, and the estimated export value. The announcement permits consolidated filing when exporting multiple technologies to the same recipient in a single transaction, while other scenarios should generally be filed separately.
One-Month Public Comment Period
The public may submit comments from October 16 to November 15, 2026, on the scope of newly added technologies, technical specifications, control policies, and facilitation measures. Feedback channels include email (
[email protected]), fax (010-65197565), and mail (Bureau of Security and Control, Ministry of Commerce, 2 Dongchang'an Avenue, Beijing, 100731). Comments submitted on behalf of organizations must bear the organization's official seal.
The legal basis for this revision is the Foreign Trade Law of the People's Republic of China and the Regulations on the Administration of Technology Import and Export. The Ministry of Commerce spokesperson emphasized that the Chinese government has consistently supported enterprises in conducting mutually beneficial cross-border operations and international technology cooperation in accordance with laws and regulations, and that the relevant policy stance remains unchanged.
From an industrial impact perspective, the 23 AI technologies represent the most significant scope of controls, touching on large language models and computing infrastructure—areas currently at the center of intense global competition. In photovoltaics, China's globally dominant polysilicon, silicon wafer, and cell manufacturing technologies are being brought under management, with the scope extending to key and core equipment that embodies these technologies. This means that not only the technologies themselves but also the hardware carriers that enable them are subject to pre-export registration.
The biomedicine sector's scope is relatively restrained at just 5 technologies, with explicit provisions that outbound licensing models qualify for automatic licensing—signaling an intent to strike a balance between promoting innovative drug exports and technology controls.
Market analysts believe the signal from this revision is that China is expanding technology export controls from traditional sensitive items to frontier technologies and sectors where it holds competitive advantages, in response to an increasingly complex geopolitical environment. At the same time, by incorporating mechanisms such as open-source exemptions, automatic licensing, and dynamic adjustment, policymakers are attempting to draw clear boundaries between security controls and industrial openness, avoiding excessive disruption to enterprises' normal international operations.
For companies involved with the relevant technologies, the immediate effectiveness of the interim registration system means the compliance window is extremely short. Enterprises need to promptly review their technology export activities, assess whether they fall within the scope listed in the announcement's annex, and complete registration during the transition period to avoid potential compliance risks.
