China Plans Controls on 23 AI Technologies: 2-Trillion-Parameter Model Exports Restricted, API Exempt

On October 16, 2026, the Ministry of Commerce and the Ministry of Science and Technology issued Announcement No. 48, proposing to add 23 artificial intelligence technologies to the Catalogue of Technologies Prohibited or Restricted from Export in China. Among them, the export of large-model weights with more than 2 trillion parameters is included in the restricted scope. Fourteen technologies are proposed for prohibition from export, and another 26 are listed as restricted from export.

The Facts

The announcement explicitly lists 14 technologies proposed for prohibition from export, including AI-driven malicious code generation and mutation technology. The 26 technologies proposed for restricted export include AI-assisted vulnerability discovery technology. The revision also involves 40 technologies in the biomedicine and photovoltaic fields, with AI accounting for 23. Already open-source models, technologies delivered through API services, and technologies disclosed in published papers are outside the control scope.

The announcement sets a public consultation deadline of November 15, while interim registration management measures take effect immediately. This follows previous rare earth export controls and marks China’s first large-scale export restrictions on core AI assets.

Mechanism Breakdown

The revision logic of the control catalogue reflects an extension from materials to algorithms: rare earth controls target physical resources, while this measure targets digital assets such as model weights. The threshold of more than 2 trillion parameters directly targets the export of weight files for frontier large models, rather than service interfaces or already public code repositories.

The exemption clauses exclude API services, open-source models, and technologies disclosed in papers. This means companies can continue to provide inference services through cloud interfaces or release open-source versions, but cross-border transfers of complete model weight files will be restricted. Interim registration management requires immediate reporting of intent to export relevant technologies.

Industry Impact

For Chinese model developers, directly licensing or selling complete large-model weights overseas will face new obstacles, while existing open-source projects and API business models are not directly affected. Concurrent controls in photovoltaics and biomedicine show that the policy covers multiple technology tracks.

Overseas partners seeking complete weights of Chinese frontier models will face higher compliance costs, while developers relying on APIs or open-source code will be less affected. The consultation period runs until November 15, during which industry stakeholders can submit feedback.

Strategic Assessment

[Analysis] The API exemption may be seen as a balanced choice between maintaining technological influence and controlling core assets. It restricts the outflow of weight files while allowing international cooperation at the service level; this arrangement is similar to the resource export model after rare earth controls, but the specific implementation effects still depend on subsequent detailed rules.