China Plans to Add 40 Technologies Including Large Language Models and Photovoltaic Silicon Wafers to Export Controls, Effective Immediately with Interim Registration – BigGo Finance

China’s Ministry of Commerce and the Ministry of Science and Technology jointly issued Announcement No. 48 of 2026 on October 16, soliciting public comments on revisions to China’s Catalogue of Technologies Prohibited and Restricted from Export. The proposal would place 40 technologies across three sectors—artificial intelligence, biomedicine, and photovoltaics—under export control, with interim pre-export registration taking effect from the date of the announcement. This represents China’s latest regulatory measure on cross-border flows of critical and core technologies amid intensifying U.S.-China technology competition.
According to the announcement, among the technologies proposed for listing, the artificial intelligence sector involves 23 technologies—the largest share—covering large language models, AI agents, computing clusters, and information processing. The photovoltaic sector encompasses 12 technologies related to polysilicon manufacturing, silicon wafer manufacturing, and cell manufacturing. The biomedicine sector includes 5 technologies related to cell and gene therapy, small nucleic acid drugs, and pathogenic microorganisms. A spokesperson for China’s Ministry of Commerce stated in response to press inquiries that the scope of the listing is precise and limited, with most technologies having clearly defined technical specifications, and that products manufactured using the relevant technologies are not within the scope of the controls.
The announcement clarifies that AI technologies that have entered the public domain through open-sourcing or publication in academic papers are not included in the control scope. For the biomedicine sector, outbound licensing models that do not involve ownership transfer are eligible for facilitation measures such as automatic licensing. The photovoltaic sector’s technology control scope also includes key and core equipment that embodies the relevant technologies.
The Ministry of Commerce spokesperson emphasized that the Chinese government supports mutually beneficial international technology cooperation and that its policy stance remains unchanged. The revision was preceded by extensive assessments organized with research institutions and industry organizations, and fully incorporated opinions and suggestions from major enterprises. The spokesperson also stated that the catalogue’s control scope will be dynamically adjusted in accordance with the law, with outdated or non-advanced technologies promptly removed based on technological developments.
Regarding the specific control design in the biomedicine sector, Hu Haitao, a researcher at the Institute of Microbiology of the Chinese Academy of Sciences, noted that the control boundaries for cutting-edge platform technologies such as cell and gene therapy and small nucleic acid drugs are very clear. The core focus is on outbound transfer of ownership of underlying platform technologies with independent intellectual property rights, aimed at preventing “uprooting-style” transfers. He believes that overseas licensing, collaborative development, and licensing transactions for specific innovative drug products and projects are not prohibited by the policy, and will be encouraged and supported through facilitation measures. “This precise control is designed to guide enterprises to transform innovation achievements into long-term international competitiveness, propel China’s biomedicine industry toward the higher end of the value chain, while protecting its own intellectual property rights,” he said.
According to the announcement, interim pre-export registration takes effect from October 16 and remains in force until the catalogue is formally revised and implemented. Circumstances requiring registration include: transferring technology ownership overseas, authorizing overseas use of domestic technology, changes in the owner or actual controller of domestic technology to a foreign entity, and other circumstances explicitly requiring registration as notified by the Ministry of Commerce. Registration information covers 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 public may submit comments from October 16 to November 15, 2026, via email, fax, or mail regarding the scope of newly added technologies, specifications, control policies, and facilitation measures. Comments submitted in the name of an organization must bear the organization’s official seal.
The distribution of technology sectors involved in this revision is as follows:
Note: Compiled from Announcement No. 48 of 2026 issued by China’s Ministry of Commerce and the Ministry of Science and Technology.
From an international perspective, this expansion of controls comes as the U.S.-China contest for dominance in frontier technologies such as artificial intelligence continues to intensify. China’s Ministry of Commerce explicitly stated in the announcement that the measures “do not target any specific country, region, or entity,” and reiterated that its position of supporting mutually beneficial international technology cooperation remains unchanged.
For industry participants, the listing of 12 photovoltaic technologies is particularly noteworthy. China occupies a dominant position in the global photovoltaic supply chain, with production capacity and technology in polysilicon, silicon wafers, and cells ranking among the world’s leaders. Placing the relevant manufacturing technologies under export controls means that cross-border transfer of core photovoltaic processes will face stricter review procedures. At the same time, the announcement explicitly states that the control scope includes key and core equipment embodying the relevant technologies, extending the control boundary from the purely technical level to hardware carriers.
The 23 AI technologies represent the largest share of this revision. Large language models and AI agents, as core competitive arenas in the current AI industry, will have a direct impact on enterprises involved in cross-border technology cooperation if their technology exports require prior registration. However, open-source models and technologies already disclosed through academic papers are explicitly excluded, which to some extent alleviates concerns in the open-source community and preserves channels for academic exchange.
The control of 5 biomedicine technologies exhibits a “precision defense” characteristic. Pathogenic microorganism technologies are placed in the prohibited export category, directly relating to national biosecurity. Cutting-edge platform technologies such as cell and gene therapy and small nucleic acid drugs focus on preventing the outbound transfer of underlying technology ownership, rather than restricting normal international cooperation and product licensing. Hu Haitao noted that in recent years China has made significant progress in niche areas such as new platform construction and new target discovery, and these new technologies also face certain risks of outflow. This listing “is a protection of innovation achievements and a consideration for the long-term development of the entire industry,” he said.
In responding to industry development concerns, the Ministry of Commerce pointed out that this listing reflects a tiered and categorized management philosophy: for technology and process platforms with independent intellectual property rights, outbound licensing and the provision of outsourced R&D and manufacturing services using the relevant technologies and processes are not included in the control scope. Exports required for public health emergencies, humanitarian relief, or joint R&D utilizing overseas resources are eligible for facilitation measures such as automatic licensing. This institutional design aims to strike a balance between security controls and international cooperation.
The implementation of the interim registration system means that, effective October 16, any export activity involving the technologies listed in the announcement—including transactions already underway but not yet completed—must be registered on the Ministry of Commerce’s unified business system platform. This “effective immediately” arrangement establishes clear compliance obligations for enterprises during the transition period before the catalogue is formally revised, while also narrowing potential room for circumvention.
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