China proposes export controls on 23 AI technologies including chip designs and model weights

On October 16, 2026, China's Ministry of Commerce proposed export controls on 23 artificial intelligence technologies, including model weights and chip designs, as part of a 40-technology revision spanning biotech and photovoltaics. Public comments run through November 15, 2026, with interim registration required immediately. While API exemptions preserve international cloud access for firms like DeepSeek and Alibaba, Beijing aims to mitigate software security risks and protect strategic assets amid ongoing competition with the U.S.

Scope and procedure of China's export control proposal

• ▪China's proposed artificial intelligence restrictions on 23 AI technologies are part of a broader revision by China's Ministry of Commerce adding 40 technologies across AI, biotechnology, and photovoltaics to its export control catalogue
• ▪On October 16, 2026, China's Ministry of Commerce issued a draft proposal to apply export controls to 23 artificial intelligence technologies, including chip designs, model weights, agents, computing clusters, and source code
• ▪Starting October 16, 2026, technology exporters in China are subject to a temporary registration requirement for covered overseas technology transfers while final rules remain pending
• ▪China's Ministry of Commerce is seeking public feedback on its proposed technology export restrictions through November 15, 2026

Exemptions and special provisions in the proposal

• ▪China's proposed export controls cover physical and overseas deployment of AI models containing restricted technology but explicitly exclude access through APIs, websites, apps, and software-as-a-service platforms
• ▪China's draft revisions October 16, 2026 to its export control catalogue include provisions to maintain simplified licensing for open-source technology exports and Chinese companies operating overseas computing centers
• ▪Artificial intelligence technology that is already in the public domain via open-source releases or academic papers is exempt from China's proposed export controls on 23 AI technologies

Cybersecurity risks motivating Chinese AI controls

• ▪China's Ministry of Commerce stated that its proposed export controls on 23 AI technologies aim to prevent the creation of autonomous systems capable of generating or modifying malicious software that threatens critical infrastructure
• ▪Concerns over frontier AI models, such as Anthropic's Mythos highlighting cyberattack potential, contributed to Beijing's push for increased national control over AI development

Biotechnology export regulations

• ▪China's draft export control revisions propose prohibiting the transfer of intellectual property ownership involving novel cell and gene therapies as well as small interfering RNA (siRNA) technologies
• ▪China's proposed export rules announced October 16, 2026 aim to support biotechnology licensing exports while protecting sensitive artificial intelligence capabilities

Chinese AI market expansion

• ▪Chinese artificial intelligence models have gained ground in foreign markets due to lower prices and improving capabilities
• ▪Chinese artificial intelligence developers have expanded international market share following releases such as DeepSeek's R1 model and Kimi K3

U.S. AI chip controls

• ▪U.S. export controls on advanced AI chips needed to train frontier models have helped American companies Anthropic and OpenAI maintain leads over Chinese AI developers
• ▪Chinese artificial intelligence developers are finding workarounds to narrow the technological gap with American rivals despite U.S. export controls on advanced chips

U.S.-China dialogue on AI and security risks

• ▪The United States and China agreed to maintain human control over decisions regarding the use of nuclear weapons during bilateral discussions on existential technology risks
• ▪Last month, the United States and China established a dedicated dialogue and incident-communications channel regarding advanced artificial intelligence