What Changed
- Public consultation initiated on adding 40 key technologies in AI, biomedicine, and photovoltaics to China's export control Catalogue.
- Categorization of controlled items into 14 technologies prohibited from export and 26 technologies restricted from export.
- Implementation of immediate interim pre-export online registration requirements for all affected technology export transactions.
On October 16, 2026, mainland China's Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology issued Announcement No. 48 of 2026, soliciting public comments on a proposed revision to the Catalogue of Technologies Prohibited and Restricted from Export. The revision is conducted pursuant to Article 20 of the Foreign Trade Law of the People's Republic of China. Alongside the consultation, authorities established mandatory interim pre-export registration management for the affected technologies.
**Scope of Proposed Export Controls**
The draft revision proposes adding 40 key technologies across three high-tech sectors, categorized into 14 prohibited and 26 restricted technologies:
1. **Artificial Intelligence (23 technologies):** Proposes prohibiting AI-driven malicious code generation and mutation technology. It proposes restricting AI-assisted vulnerability discovery technology and other technologies across large models, intelligent agents, computing power clusters, and information processing.
2. **Biomedicine (5 technologies):** Proposes prohibiting proprietary cell and gene therapy technology and process platforms. It proposes restricting proprietary target discovery and validation technologies for universal cell and gene therapies, small nucleic acid drugs, and pathogenic microorganism technologies.
3. **Photovoltaics (12 technologies):** Proposes prohibiting production technology for perovskite and tandem cell modules. It proposes restricting polysilicon engineering technology with a single-line production capacity of 30,000 tonnes per year or greater, alongside controls on specific key photovoltaic equipment carrying restricted technologies.
**Interim Registration and Facilitation Measures**
Effective from the issuance of Announcement No. 48 of 2026 on October 16, 2026, until the formal revision takes effect, technology export operators must register covered transactions on MOFCOM's online Technology Trade Management Information Application platform prior to export. Registration applies to technology ownership transfers, foreign licensing, changes of actual controller to foreign entities, ongoing uncompleted exports, and key photovoltaic equipment carrying controlled technologies.
Facilitation measures, such as automatic licensing ('immediate approval upon filing'), will apply to low-risk scenarios, including open-source AI releases, cross-border joint R&D, overseas deployment on self-owned clouds, outbound licensing for certain biomedicine targets, and exports needed for public health emergencies or humanitarian assistance. Providing external parties with API invocations, SaaS, or app interactions using restricted models without transferring underlying technology does not fall within the scope of technology export management.
Who May Be Affected
Technology export operators, AI developers, biomedicine companies, photovoltaic equipment manufacturers, and entities engaging in cross-border technology transfers or foreign licensing with mainland China.
Cross-Border Context
Applies to technology exports from mainland China to overseas parties, foreign licensing, changes of technology ownership to foreign entities, cross-border joint R&D, and overseas localized deployment of restricted technologies.
What to check next
- Check the original text of Announcement No. 48 of 2026 for specific technical indicator thresholds and public comment submission deadlines.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.