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China proposes export curbs on 23 AI technologies, but leaves API access to models out

Running a restricted Chinese model abroad would count as an export, while selling access to it over an API wouldn't.

On October 16, 2026, China's Ministry of Commerce and Ministry of Science and Technology proposed adding 40 technologies to the country's catalogue of technologies banned or restricted from export. Twenty-three of them are in AI, covering large models, agents, computing clusters and information processing.

Comments are open until November 15. Registration starts now. Anyone exporting a listed technology has to log it with the commerce ministry before it goes, and that includes deals already under way.

Issued
Oct 16, 2026
Technologies
40, of them 23 in AI
Comments
Oct 16 to Nov 15
Registration
from Oct 16

What's on the AI list

A wide, pale stone office block with rows of square windows and a dark overhanging roof, behind a gold-colored roadside railing on a broad, empty avenue
China's Ministry of Commerce in Beijing, which issued the proposal with the science ministry. Photo: N509FZ, CC BY-SA 4.0, via Wikimedia Commons

The full list sits in an attachment I haven't been able to read, so this goes on the announcement and a Q&A the ministry's spokesperson published the same day. Both are in Chinese.

The spokesperson picked out one AI item for an outright ban: using AI to generate and mutate malicious code. AI-assisted vulnerability hunting is restricted instead, so you'd need a license.

Why? Safety, mostly. In the spokesperson's account, tools like these could be turned on the country's critical information infrastructure, or on defense and core government systems, and non-state actors could do real damage with them. Keeping AI under human control is the stated aim.

What stays outside it

Open-source releases and published papers aren't covered. Most AI technology could still be exported freely once the rules are in force, the spokesperson said.

If you use a Chinese model from outside China, here's how it splits. A company deploying a restricted large model locally in another country is exporting technology. Offering that same model through an API, an app, a web page, a SaaS product or a slimmed-down on-device version isn't an export at all.

Some exports would get an automatic license (roughly, report it and it can ship). Those include open-sourcing AI technology, Chinese companies running their own computing centers abroad, having chips manufactured overseas and joint research that uses foreign resources.

The spokesperson called the revision routine work the two ministries have done many times since 2001, and said it isn't aimed at any particular country. The announcement gives no date for the revised catalogue to take effect.

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