China proposes export controls on 23 AI technologies and chip designs
Beijing’s ministries draft rules to restrict exports of large models, agents, and advanced silicon, while exempting open-source code.
Key points
- China’s commerce and science ministries proposed adding 23 AI technologies to the export control list.
- Controls target models with at least 2 trillion parameters or those ranking in the global top 10.
- Open-source software and published research are exempt from the proposed restrictions.
China’s Ministry of Commerce and Ministry of Science and Technology proposed a draft on Friday to add 23 artificial intelligence technologies to the country’s export control list. The proposal aims to restrict the overseas transfer of large language models, AI agents, and specific chip designs.
The draft covers 40 items in total, including 12 solar technologies and five biomedicine items such as gene therapy. According to Bloomberg, the AI restrictions apply to models with at least 2 trillion parameters. They also cover models that rank in the world’s top 10 on performance and safety tests.
Scope of Restrictions
The proposal targets core components of large models, including weights and source code. It also limits design know-how for AI chips manufactured at 14 nanometres or below. Additionally, it covers chips built using 2.5D or 3D stacking techniques. Some memory chip designs are included in the list as well.
Running a covered model on servers located outside China would count as an export under the draft. However, firms operating their own cloud servers abroad could receive an automatic licence. The rules do not name specific models, but Bloomberg and the Associated Press noted that Moonshot AI’s Kimi K3 and Alibaba’s Qwen3.8-Max exceed the size threshold.
Exemptions and Process
Open-source code and published research are explicitly exempt from the export controls. Chinese companies can continue to serve overseas users through applications, websites, and APIs. A temporary export registration rule took effect on 16 October, requiring firms to register before exporting listed items.
The public can submit comments on the draft until 15 November. A ministry spokesperson stated the rules aim to prevent misuse and ensure AI remains under human control. The ministry added that the plan does not target any specific country or firm.
What should you do?
Organizations relying on Chinese AI models or hardware should monitor the finalization of these rules. Verify whether your current supply chain involves controlled items. Review contracts for clauses related to export compliance. Prepare to document the origin of model weights and chip designs.
Background: Large language models
Large language models are a specific type of neural network trained on text. Generative AI is the broader umbrella term for any system that creates new content, including images and code. Not all generative AI uses large language models, but most modern text generators do.
What to do and how to stay safe: China
- Audit your technology stack to identify any AI models or hardware originating from China that may meet the parameter or size thresholds.
- Review vendor contracts to understand how export controls might affect service availability, especially for cloud-based AI services.
- Monitor official government publications for the final version of the export control list after the public comment period ends.
- Ensure your internal documentation clearly distinguishes between open-source components and proprietary models to facilitate compliance checks.
Step-by-step guide: Prompt Injection Warning Signs: How to Spot AI Manipulation
General security guidance from the Threat Times newsroom. It is not confirmed advice from the organisations named in this story.
Frequently asked questions
Which AI models are affected by the proposed export controls?
Models with at least 2 trillion parameters or those ranking in the global top 10 on performance and safety tests are subject to the controls.
Are open-source AI models included in the export restrictions?
No, the draft proposal explicitly exempts open-source code and published research from the export control list.
When can the public comment on the draft proposal?
The public can submit comments on the draft proposal until 15 November.
