China Proposes Export Controls on 40 AI, Biomedicine and Solar Technologies

New rules would govern what technology leaves China

China proposed export bans or licensing requirements for 40 technologies on October 16, 2026, while immediately requiring exporters to register covered transfers abroad. The package includes 23 artificial intelligence technologies, 12 solar technologies and five biomedicine technologies, reaching from advanced AI models and chip designs to gene therapies and solar manufacturing equipment.

The Ministry of Commerce and Ministry of Science and Technology opened public consultation through November 15 under their joint Announcement No. 48 of 2026. Their proposed revision to the Catalogue of Technologies Prohibited and Restricted from Export would place 14 technologies in the prohibited category and 26 in the restricted category, where exports would require permission.

The immediate change for businesses is registration. Companies transferring covered technology must submit information to the commerce ministry while the broader rules are being considered. Transactions already started but not completed are included, alongside new agreements.

For foreign AI developers, drug companies and solar manufacturers, the central issue is how technology crosses the border. Downloading a sensitive model, buying intellectual property or acquiring control of a technology owner could face different requirements from using an online service or licensing a medical technology without taking ownership.

Beijing says the revision is routine technology trade management and targets no particular country, region or entity. It arrives during intensifying competition with the United States, Europe and Japan over advanced chips, manufacturing expertise and access to increasingly capable AI systems.

What the two levels of control mean

The ministries are proposing the changes under China's Foreign Trade Law and Regulations on Administration of Technology Import and Export. The catalogue separates technologies that cannot be exported from those that may be exported with a licence.

The proposed prohibited category includes AI technology for generating and modifying malicious computer code, certain proprietary cell and gene therapy platforms, and production technology for perovskite and tandem solar cell modules. Perovskites are materials used to absorb light, while tandem cells combine multiple light absorbing layers to capture more sunlight.

The restricted category includes AI tools for finding software vulnerabilities, certain technologies for discovering and validating new treatment targets, and polysilicon engineering technology for a production line with annual capacity of at least 30,000 tonnes. These examples show how the rules use technical capabilities and production thresholds to determine coverage.

AI accounts for 57.5% of the 40 proposed entries, solar technology for 30% and biomedicine for 12.5%. Those shares describe the number of listed technologies. Companies will need to check the individual definitions and thresholds to determine which products, agreements or research activities fall within them.

Which AI capabilities would face scrutiny?

The 23 AI entries cover large models, intelligent agents, computing clusters, information processing and certain chip design technologies. Large models learn patterns from extensive collections of data. Agents use models to carry out tasks, while computing clusters connect many processors so they can train or run large systems together.

The proposal would prohibit exports of core technology for models trained using sensitive Chinese national data. It also identifies agents designed for highly sensitive environments, including national defence and critical information infrastructure. These are systems such as communications and energy networks whose disruption could cause widespread harm.

Other models could require a licence because of their size or capabilities. The proposed criteria include models with at least one trillion parameters and models meeting certain leading performance standards. Parameters are numerical settings learned during training that help determine how a model responds; performance also depends on its design, training data and computing resources.

Model weights, the learned numerical settings inside a trained model, and source code could fall within controls when the relevant thresholds are met. Certain design technologies for AI processing chips and memory chips would also face restrictions. Final technical definitions, performance thresholds and the catalogue's implementation date have not been settled.

The Ministry of Commerce linked the proposal to the risk of AI attacking critical infrastructure, defence systems and core government networks. A ministry statement described the purpose of the measures:

The Chinese government is implementing such necessary measures with the aims of reinforcing the security bottom line, preventing misuse and abuse, and ensuring that AI remains under human control.

Using an AI service would remain different from taking its technology

The proposal excludes access through application programming interfaces, websites, apps and software as a service platforms. An application programming interface, usually called an API, lets another program send a request to a model running on the provider's computers and receive a response.

A company using such a service leaves the underlying model with its provider. A company downloading model weights can instead run a copy on its own equipment. The proposed rules focus on transfers of restricted technology from China to another country, including overseas deployment of models containing that technology.

The ministry says most AI technologies would remain freely exportable. Technology already in the public domain through open source releases or academic papers would be excluded. Simplified licensing would be available for certain open source technology exports and Chinese companies operating their own computing centres overseas.

For developers choosing between downloading a model and paying for hosted access, those boundaries matter. Hosted services could continue reaching foreign customers while transfers of sensitive model technology receive closer review. Existing public releases would remain outside the proposed controls, while future releases would require assessment against the applicable criteria.

Why overseas demand makes the AI rules consequential

Chinese models have gained international users through lower prices and improving capabilities, particularly since DeepSeek released its R1 model in early 2025. Their expansion has made downloadable models and the technology behind them a more valuable part of China's export economy.

Chinese models accounted for 17.1% of global downloads of models with publicly available weights in the year to August 2025, compared with 15.8% for US models. DeepSeek and Alibaba's Qwen together accounted for 14%. The Chinese share exceeded the US share by 1.3 percentage points.

Usage figures from OpenRouter, a platform that routes requests to different AI models, show another part of that expansion. Chinese origin models accounted for at least 30% of weekly US enterprise token volume on that platform from February 8, 2026, reaching a peak of 46%, compared with 4.5% in early 2025. Tokens are the pieces of text that models process or generate; the figures describe activity on that platform.

Authorities had discussed possible restrictions on overseas access to advanced Chinese models with companies including Alibaba, ByteDance and Z.AI before the October announcement. Discussions also covered training data transfers, protection against theft of proprietary AI technology and screening foreign investment in domestic AI startups.

The commercial choice is concrete: a foreign customer might continue buying answers from a Chinese model through an API while facing additional requirements to obtain and operate the underlying technology independently.

Biomedicine rules separate ownership from collaboration

The five biomedicine entries cover cell and gene therapies, small nucleic acid drugs and pathogenic microorganisms. Cell therapies use living cells to treat disease. Gene therapies introduce or alter genetic material, while small nucleic acid medicines act on the biological instructions involved in producing proteins.

The proposal would prohibit transfers of intellectual property ownership involving certain novel cell and gene therapies and small interfering RNA technologies. Small interfering RNA, or siRNA, can reduce production of a particular protein by targeting the genetic message used to make it.

Other activities would receive different treatment. Overseas licensing that leaves ownership with the Chinese technology holder could qualify for automatic licensing or other simplified procedures. For specified proprietary platforms, some licensing arrangements and services involving outsourced research, development or production would be outside the management scope.

Those provisions preserve routes for international cooperation while placing tighter limits on permanent transfers of sensitive intellectual property. A foreign pharmaceutical company licensing a technology for use in an agreed market could therefore face different requirements from a buyer acquiring ownership of the platform itself.

The restricted list also includes certain technologies for discovering and validating new treatment targets in cell and gene therapy. A target is a biological feature, such as a protein or gene, that a treatment is designed to affect. Finding and checking a new target can be a valuable early step in developing a medicine.

Solar controls reach manufacturing methods and equipment

The 12 photovoltaic entries cover polysilicon production, silicon wafer manufacturing and solar cell manufacturing. Photovoltaics is the technology that converts sunlight into electricity. Polysilicon is a purified form of silicon used to produce the wafers from which many solar cells are made.

The proposed controls also cover key equipment that carries or embodies the listed technologies. That means a transaction may require review because of the manufacturing knowledge built into a machine, alongside transfers of technical documents or intellectual property.

The proposed prohibition on perovskite and tandem module production technology differs from the licensing requirement for qualifying polysilicon engineering technology. The ministry says technologies below the relevant control thresholds would remain freely exportable.

Chen Gang, chairman of Shanghai Aiko Solar Energy, argued that the measures focus on advanced technology and core equipment while leaving mature manufacturing technology and equipment open to global markets. He said licensing could protect innovation and encourage competition based on quality and technological value rather than expanding production and cutting prices.

Chen also acknowledged that exporters of advanced equipment could face adjustments in the short term. The ministry cited the growing use of solar technology in aerospace, defence, unmanned equipment and infrastructure with high security requirements as reasons for closer supervision.

What exporters must register now

The interim registration requirement began on October 16 and will continue until the revised catalogue formally takes effect. Exporters must register covered transactions through the technology trade management application on the Ministry of Commerce's unified business platform before carrying out the export.

Registration covers transfers of technology ownership, licences allowing technology held in China to be used overseas, and changes that place the technology's owner or actual controller under a foreign entity. The ministry can also specify other situations requiring registration.

Companies must provide basic information about the exporter and recipient, the destination country or region, the technology and intended use, and its estimated export value. Multiple technologies going to the same recipient in a single transaction may be registered together; other transactions should generally be filed separately.

Acquisitions have already brought these issues into focus. Meta announced an acquisition of the Chinese founded AI agent company Manus for roughly $2 billion in late December 2025. China's National Development and Reform Commission ordered the transaction unwound in April 2026, citing foreign investment and technology export rules. By June, Meta had cut Manus off from its internal data systems.

The registration rules expressly include changes in actual control. A foreign acquisition can therefore come within the system even when the transaction is structured as a purchase of a company rather than a direct sale of technology.

The consultation follows a wider contest over technology

US restrictions have limited China's access to advanced AI chips and the equipment used to manufacture them. Europe and Japan also control exports of sensitive technologies, while China has imposed controls on critical minerals. The new proposal extends Beijing's management of outbound technology across software, medical research and solar manufacturing.

AI safety discussions have continued alongside that competition. China and the United States have agreed to keep humans in control of nuclear weapons decisions and established a dialogue and an incident communications channel for advanced AI in September 2026.

Tian Xue Su, a chief analyst at technology research group Omdia, viewed the proposal as a response to Western demands for greater national control over AI and other technologies. Mary Ng, a senior economist at Natixis, described the wider trend:

The world is getting more fragmented in trade and investment, but also in access to technologies.

The next steps and relevant milestones are:

• July 1, 2026: China began implementing tighter rules on overseas investment and outbound transfers of technology, data and related expertise.
• October 16: The ministries published the proposed catalogue changes and began interim registration.
• October 16 to November 15: The public can comment on coverage, thresholds, control policies and simplified procedures.
• November 15: The consultation closes. Interim registration continues until the revised catalogue takes effect.

Comments can be submitted by email, fax or letter to the ministry's Security and Control Bureau. Organisations submitting comments must include their official seal. For businesses, the immediate task is identifying covered transfers already in progress while assessing how the proposed ownership, licensing and service boundaries affect future agreements.

Key Points

• China proposes controls on 40 technologies: 23 in AI, 12 in solar manufacturing and five in biomedicine.
• Fourteen technologies would be prohibited from export; 26 would require licensing.
• Interim registration already covers relevant technology transfers, overseas licences and changes in foreign control, including unfinished transactions.
• Hosted AI access through APIs, websites, apps and software as a service would remain outside the proposed scope.
• AI technology already in the public domain would be excluded, while some medical licensing arrangements would receive simplified treatment.
• Public consultation closes on November 15, 2026. The final catalogue's implementation date has not been announced.