On October 16, 2026, MOFCOM and the Ministry of Science and Technology issued Announcement No. 48 of 2026, soliciting public comments on the revision of the Catalogue of Technologies Prohibited and Restricted from Export (hereinafter referred to as “the Catalogue”), and implementing interim management measures requiring pre-export registration for relevant technologies. A MOFCOM spokesperson recently answered questions from reporters on relevant issues.

Q: What is the background of the revision of the Catalogue?

A: According to Article 20 of the Foreign Trade Law of the People’s Republic of China, the competent department of foreign trade under the State Council, along with other relevant departments under the State Council, formulates, adjusts and publishes the catalogue of technologies prohibited and restricted from export. Since 2001, MOFCOM, together with the Ministry of Science and Technology, has revised the Catalogue on multiple occasions, with technologies added and removed, controls tightened and relaxed, thereby establishing a regular working practice. This revision is also routine work in technology trade management, carried out in accordance with laws and regulations, and does not target any specific country, region or entity.

In recent years, the application of artificial intelligence, biomedicine and photovoltaic-related technologies in sensitive fields has continued to expand, and major economies have all implemented export controls to varying degrees. With reference to common international practices, China implements necessary management in accordance with the law, which not only prevents the risks of technology getting out of control and improper proliferation, but also safeguards normal international technological exchanges and cooperation, and promotes science and technology development that is positive, beneficial, safe, controllable, and conducive to the well-being of humanity.

Q: What is the scope of technologies proposed to be added to the Catalogue?

A: This public consultation covers 40 key technologies proposed to be added in three fields: artificial intelligence, biomedicine and photovoltaics. Among them, 14 technologies are proposed to be prohibited from export, including AI-driven malicious code generation and mutation technology, proprietary cell and gene therapy technology and process platforms, and production technology for perovskite and tandem cell modules; 26 technologies are proposed to be restricted from export, including AI-assisted vulnerability discovery technology, proprietary discovery and validation technology for new targets of universal cell and gene therapy, and polysilicon engineering technology with a single-line production capacity of 30,000 tonnes per year or greater. The announcement also specifies circumstances under which facilitation measures apply. For details, please refer to the original text of the announcement.

Q: Does the revision of the Catalogue fully take into account the industry’s development?

A: The Chinese government has always supported enterprises in carrying out mutually beneficial transnational operations and international technological cooperation in accordance with laws and regulations, and its relevant policy position remains unchanged. With respect to the scope of technologies and policies under this public consultation, MOFCOM and the Ministry of Science and Technology, together with competent authorities in charge of specific sectors, had organized research institutions and industry organizations in advance to conduct in-depth assessments, and had fully solicited the opinions and suggestions of major enterprises, fully taking into account the current situation and development needs of industries at home and abroad. This is reflected in three aspects: First, the scope of control is precise and limited. Most of the technologies proposed for control this time have specific technical indicators, and products manufactured using the relevant technologies are not within the scope of management. The scope of management is clear, precise, and limited, setting compliance boundaries for enterprises and facilitating policy implementation. Second, facilitation measures apply. The revision of the Catalogue identifies various export circumstances to which facilitation measures are intended to apply, reflecting a tiered and categorized management approach, which helps enhance the transparency and predictability of policies and ensures that technology export is secure, standardized and orderly. Third, dynamic adjustment is implemented. MOFCOM and the Ministry of Science and Technology will, in accordance with the law, dynamically adjust the scope of management of the Catalogue, and remove technologies that are not advanced from the Catalogue in a timely manner as technologies develop. This public consultation is an arrangement to solicit opinions and suggestions from all parties on a broader scale.

Q: What are the main considerations behind the proposed addition of artificial intelligence technologies?

A: At present, global AI technological innovation has entered an unprecedentedly active period, facing both opportunities and challenges. This time, 23 key technologies related to AI large models, intelligent agents, computing power clusters and information processing are proposed to be added to the Catalogue. The main considerations are as follows:

The first consideration is to ensure that AI technology is safe and controllable. Various endogenous and derived risks brought about by AI have attracted great attention from countries around the world. The AI-autonomously-driven malicious code generation and mutation technology proposed for control this time can be used to attack sensitive systems such as national critical information infrastructure, national defense and military industry, and core government affairs, or to bypass national security defense systems. If acquired by non-state actors or malicious entities, it may harm national security and the common security of humanity. The Chinese government implements necessary management of such technologies in order to firmly safeguard the bottom line of security, prevent abuse and misuse, ensure that AI always remains under human control, and advance international AI governance.

The second consideration is to encourage open-source development, collaboration, and sharing. The Chinese government is committed to making AI an important driving force for promoting common prosperity and safeguarding common security. To support the building of an open-source AI innovation ecosystem, facilitation measures such as automatic licensing apply to technology exports in circumstances such as open-sourcing AI technologies, Chinese enterprises building and operating their own computing power centers overseas, conducting chip tape-out and manufacturing overseas, cross-border joint R&D, and participating in the formulation of international standards, basically realizing “immediate approval upon filing.” It is also proposed that relevant technologies that have entered the public domain through open-source release, publication of academic papers and other means will not be included in the scope of export management, so as to create a favorable environment for international AI technological exchanges and cooperation.

It should be particularly noted that China advocates engaging in dialogue and cooperation on artificial intelligence with all countries—based on the principles of mutual respect, equality, and mutual benefit—to jointly address the risks associated with the proliferation and potential loss of control of AI technologies. China supports countries of the Global South in strengthening their AI capacity to bridge the digital-intelligence divide and promote sustainable development. Furthermore, China will provide greater facilitation and support for technology exports necessary for international capacity-building cooperation, technology sharing, and the joint development of rules among members of the World Artificial Intelligence Cooperation Organization.

Q: After the Catalogue is formally implemented, will various forms of “going global” by AI large models, such as overseas localized deployment and providing model invocation services to overseas parties, fall within the scope of technology export management?

A: At present, there are various modes for AI large models and application products to “go global.” The core of determining whether a specific “going global” circumstance falls within the scope of technology export management lies in whether it involves the transfer of restricted technologies from within China to outside China.

The scope of AI technologies that fall under regulation this time is precise and limited. After the relevant measures are formally implemented, the vast majority of AI technologies can still be exported freely. For AI technologies included in the restricted category, carrying out overseas localized deployment falls within the scope of technology export management; if deployed in circumstances with relatively controllable risks, such as on overseas self-owned clouds, facilitation measures such as automatic licensing may apply. For circumstances in which enterprises use restricted large models to provide API invocation, APP/webpage interaction, SaaS applications, local device-side lightweight deployment and other services to external parties, they do not fall within the scope of large-model technology export management.

Q: What are the main considerations behind the proposed addition of biomedicine technologies?

A: The current Catalogue already includes some biomedicine technologies. This time, five other technologies related to pathogenic microorganisms, cell and gene therapies, and small nucleic acid drugs are proposed to be added. The main considerations are as follows:

The first consideration is to safeguard human life, health and safety. Technologies such as pathogenic microorganism technology are directly related to human health and national biosafety. Including them in the Catalogue for prohibition of export is an institutional arrangement for safeguarding national security and building a biosafety barrier, and also an objective need for protecting the health of all humanity.

The second consideration is to support the orderly development of international cooperation on China’s biomedicine technologies in accordance with laws and regulations. In controlling biomedicine technologies this time, important circumstances of international cooperation are excluded or subject to facilitation measures. For example, for relevant technology and process platforms with proprietary intellectual property rights, export circumstances such as outbound licensing and using relevant technologies and processes to provide outsourced R&D and production services are not included in the scope of management; for relevant target discovery and validation technologies with proprietary intellectual property rights, exports by way of outbound licensing are subject to facilitation measures such as automatic licensing.

The third is to practice the philosophy of a global community of health for all. This policy explicitly stipulates that for technologies restricted from export, exports needed for public health emergencies, humanitarian assistance, and joint R&D using overseas resources are subject to facilitation measures such as automatic licensing. China will continue to share the outcomes of technological development with countries around the world and make positive contributions to improving human health and well-being.

Q: What are the main considerations behind the proposed addition of photovoltaic technologies?

A: This time, 12 photovoltaic technologies in areas such as polysilicon manufacturing, silicon wafer manufacturing and cell manufacturing are proposed to be added to the Catalogue. The main considerations are as follows:

The first consideration is to safeguard national security and interests. In recent years, the application of photovoltaic technologies in sensitive fields such as aerospace, national defense, unmanned equipment and high-security-level infrastructure has continued to expand, and the national security risks that may be caused by photovoltaic technology exports have continued to rise, making it necessary to implement timely and appropriately scaled regulation.

The second is to support the sharing of green technologies. The scope of technologies listed under control this time is limited, and other technologies that do not reach the control indicators can still be exported freely. The announcement lists a small number of key photovoltaic equipment, only targeting circumstances where they carry technologies that reach the control indicators. Other photovoltaic equipment not listed is, in principle, not subject to the requirements of this announcement.

The third is to improve the technology export supervision system. The export of key photovoltaic technologies often occurs alongside the export, installation, commissioning, improvement and upgrading of photovoltaic production lines. Export operators engaged in the above activities shall apply for technology export licenses in accordance with regulations and, on the strength of such licenses, complete foreign exchange, banking, tax, customs and other relevant procedures.

Q: What are the main considerations and specific requirements for implementing pre-export registration management for the technologies proposed to be added?

A: In order to understand the demand for relevant technology exports, improve scientific management, and prevent potential export risks, in accordance with the relevant provisions of Articles 18 and 20 of the Foreign Trade Law of the People’s Republic of China, and upon approval, from the date of issuance of Announcement No. 48 of 2026 by MOFCOM and the Ministry of Science and Technology to the date of implementation of the formal revision announcement of the Catalogue of Technologies Prohibited and Restricted from Export, technology export operators shall, before exporting the technologies listed in the announcement, register in the Technology Trade Management Information Application on the unified platform of MOFCOM services system. Export operators shall determine on their own whether the technologies to be exported fall within the scope of interim registration management. Exports that have begun but have not yet been completed fall within the scope of registration. Export circumstances requiring registration include: transferring technology ownership to overseas parties, authorizing overseas use of domestic technologies, changing the owner or actual controller of domestic technologies to an overseas entity, and other circumstances explicitly required by MOFCOM to be registered. It should be particularly noted that exports of key and core photovoltaic equipment included in the scope of management of the Catalogue must all be registered in accordance with regulations. Enterprises encountering problems and difficulties in registration may consult MOFCOM and the Ministry of Science and Technology in a timely manner. (Released on October 16)