On October 16, 2026, the Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST) of China issued the Announcement No. 48 of 2026 (hereinafter referred to as "the Announcement"), launching the public consultation on the proposed revision of the Catalogue of Technologies Prohibited and Restricted from Export (hereinafter referred to as "the Catalogue").

The proposal covers 40 technologies across three sectors — 23 in artificial intelligence (AI), five in biomedicine and 12 in photovoltaics (PV) — of which 14 are proposed to be prohibited from export and 26 to be restricted, meaning exportable only upon a government license. Comments will be accepted until November 15, 2026.

Meanwhile, a temporary pre-export registration requirement has taken effect from the date of the Announcement. Exporters must register covered technology transfers through MOFCOM's technology trade management information system before proceeding. The requirement covers exports already started but not yet completed, and includes four types of transactions:

• overseas transfer of technology ownership;

• licensing domestic technology for overseas use;

• change of the owner or actual controller of domestic technology to an overseas entity;

• and other circumstances specified by MOFCOM.

Artificial intelligence

The proposed AI entries cover large models, AI agents, computing clusters, information processing and chip design. The key points are summarized as follows:

Ÿ   Large models trained with China's "core data" are proposed to be prohibited from export, and those trained with "important data" to be restricted. Core technologies of models meeting any of the three criteria — computation of 10²⁶ floating-point operations, parameters of two trillion, or "globally leading" capability (top 10 in public evaluations at the time of export) — including weight parameters, key checkpoints, underlying source code, architecture design and training and inference optimization, would be restricted.

Ÿ   High-performance AI agents used in critical information infrastructure, defence and other highly sensitive scenarios are proposed to be prohibited; technologies enabling autonomous planning, multi-agent coordination, tool invocation and game decision-making at specified performance levels would be restricted.

Ÿ   AI processor chip design technologies, including those using 14 nm or below manufacturing processes, 2.5D/3D packaging and non-von-Neumann architectures, as well as advanced 3D flash and memory chip design technologies, would be restricted.

Ÿ   High-speed interconnection, fault-tolerance and communication scheduling technologies for large-scale computing clusters of more than 10,000 AI accelerator cards would be restricted.

Ÿ   AI-driven malicious code generation and mutation technologies are proposed to be prohibited.

Technologies already in the public domain through open-source release or academic publication are excluded from the control. Automatic licensing is proposed for low-risk scenarios including open-source release, self-built and self-operated overseas computing centres of Chinese companies, overseas chip fabrication, joint R&D using overseas resources and participation in international standard-setting. MOFCOM further clarified that providing model access to overseas users through APIs, apps, websites or SaaS does not constitute a technology export, whereas localized overseas deployment of a restricted model does; deployment on a company's own overseas cloud may qualify for the facilitation measures.

Biomedicine

Three entries are proposed to be prohibited: proprietary cell and gene therapy (CGT) technology process platforms, proprietary siRNA drug technology process platforms, and artificial genetic modification and directed serial-passage gain-of-function technologies for pathogenic microorganisms. Notably, the two platform entries prohibit only the overseas transfer of ownership: licensing, outsourced R&D and manufacturing services that do not transfer ownership, and technologies necessary for cooperation and business development of specific drug products are excluded. Two restricted entries cover discovery and validation technologies for entirely novel targets of CGT and siRNA, for which automatic licensing is proposed for outbound licensing and joint R&D using overseas resources.

Photovoltaics

The twelve PV entries cover polysilicon, wafer and cell manufacturing. Proposed prohibitions include large-capacity trichlorosilane cold-hydrogenation and silane fluidized bed processes, wafer preparation technologies of 70 μm and below, edge passivation technologies and perovskite and tandem module production technologies. Proposed restrictions include polysilicon engineering technology with single-line capacity of 30,000 tons per year or above, large monocrystal furnace design, ultra-thin large-size wafer preparation, and TOPCon, XBC and HJT cell manufacturing technologies. The control scope also covers key and core equipment carrying the listed technologies.

Implications for foreign stakeholders

The Announcement does not restrict the export of finished products manufactured with the listed technologies; ordinary trade, procurement and SaaS-based services are generally unaffected. However, for foreign investors and MNCs, transactions involving the acquisition of Chinese technology companies, licensing-in of Chinese technology, or overseas factory projects relying on Chinese process packages and equipment should be reviewed against the proposed entries, keeping in mind that a change of actual control over the technology — even without any cross-border data transfer — may trigger registration. Compliance teams are advised to check ongoing and planned transactions, reflect registration and licensing conditions in deal terms, and monitor the final version of the Catalogue, as several concepts (including the identification of "important data" and the criteria for "globally leading" capability) remain to be clarified. Stakeholders may also submit comments through the channels announced by MOFCOM before November 15, 2026.

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