China’s Ministry of Commerce and the Ministry of Science and Technology issued a joint announcement on October 16, 2026, soliciting public comments on revisions to the Catalogue of Technologies Prohibited and Restricted from Export in China, while simultaneously implementing interim pre-export registration management for 40 technologies spanning artificial intelligence, biomedicine, and photovoltaics. This represents a concentrated expansion of China’s critical technology export control framework, directly touching the most fiercely contested frontiers of global technology competition.
The announcement stipulates that from the date of issuance until the catalogue revisions are formally implemented, technology exporters must complete registration on the Technology Trade Management Information Application within the Ministry of Commerce’s unified business system platform before exporting technologies listed in the catalogue. Exports that have already commenced but not yet been completed are also subject to registration requirements.
Among the proposed additions, the artificial intelligence sector accounts for the largest share, covering 23 technologies related to large language models, AI agents, computing power clusters, and information processing. The announcement also establishes an important exclusion clause: technologies that have already entered the public domain through open-source releases, academic paper publications, or similar means are not subject to management. This means normal exchanges within the open-source community and academia will not be directly impacted by the new regulations.
The biomedicine sector covers 5 technologies including cell and gene therapy, small nucleic acid drugs, and pathogen-related technologies. Addressing the outbound licensing collaboration model common in the biopharmaceutical industry, the announcement introduces differentiated arrangements: outbound licensing models that do not involve ownership transfer are eligible for facilitation measures such as automatic licensing. This design aims to preserve channels for cross-border license-out transactions by innovative drug companies, avoiding excessive restrictions on normal commercial technology collaboration.
The photovoltaic sector’s control scope covers 12 technologies related to polysilicon manufacturing, silicon wafer manufacturing, and cell manufacturing, with critical and core equipment supporting these technologies also brought under management. China holds dominant global production capacity in polysilicon, silicon wafers, and cell segments, and the risk of technology spillover in related manufacturing processes and equipment has previously drawn attention from multiple parties.
Registration is required in four specific scenarios: transferring technology ownership to overseas entities (such as intellectual property transfers); authorizing overseas use of domestic technology (such as IP licensing); changes in ownership or actual control of domestic technology to overseas entities; and other circumstances explicitly requiring registration as notified by the Ministry of Commerce.
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 of the technology. The announcement permits consolidated filing when exporting multiple technologies to the same recipient in a single transaction; other circumstances should generally be filed separately.
The public comment window runs from October 16 to November 15, 2026, a period of one month. The public may submit comments via email, fax, or mail regarding the scope of newly added technologies, indicators, control policies, and facilitation measures. Comments submitted on behalf of an organization 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 of the People’s Republic of China on the Administration of Technology Import and Export. From a policy trajectory perspective, China has been continuously refining its technology export control system in recent years, having previously imposed export controls on rare earth processing, drones, and certain advanced materials. The inclusion of AI infrastructure technologies such as large language models, AI agents, and computing power clusters in the proposed control list reflects policymakers’ heightened emphasis on technological sovereignty and security boundaries in the AI domain.
For industry participants, the interim registration management will create a transition period before the catalogue formally takes effect. Cross-border technology transfers, overseas licensing, and control changes involving the aforementioned technologies will require advance compliance planning. Companies in the AI sector, in particular, will need to reassess whether overseas technology collaborations or structural adjustments trigger registration obligations.
Notably, the announcement establishes exclusions or facilitation arrangements for open-source technologies, academic publications, and outbound licensing that does not involve ownership transfer, indicating that policymakers are attempting to strike a balance between technology security and innovation openness. The specific indicator details in the final catalogue and the implementation standards for facilitation measures will become key compliance focal points for enterprises going forward.
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