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China proposes export controls on 23 AI technologies: weights of 2T-parameter or global top-10 models restricted, open source and API services exempt
On Oct 16 China's commerce and science ministries proposed adding 40 technologies, 23 of them in AI, to the export ban and restriction catalogue. The draft restricts core technology of models with at least 10^26 training FLOPs, at least 2 trillion parameters, or a global top-10 ranking, and sets step, concurrency and tool-count thresholds for agents. Open-sourced technology is exempt, and API or SaaS services are not treated as technology exports. Temporary pre-export registration took effect the same day; comments close Nov 15.
Key Takeaways
- 23 AI items out of 40 proposed technologies (14 prohibited, 26 restricted across AI, biomedicine and photovoltaics); comments open Oct 16 to Nov 15, 2026
- Restricted model thresholds (any one): at least 10^26 training FLOPs, at least 2 trillion parameters, or a global top-10 ranking; covers weights, checkpoints, source code, architecture and training or inference acceleration
- Agent thresholds include 20 or more sub-task steps with at least 90% average success, 60 or more concurrent agents, or 200 or more integrated tools
- Open-sourced or published technology is exempt; serving via API, app or web, SaaS, or lightweight on-device deployment is not a technology export, while overseas on-premise deployment is
- Temporary pre-export registration has applied since Oct 16, including deals already underway