China drafts export curbs on AI models and chip designs
China's draft adds 23 AI technologies to its export control list, from models with 2 trillion parameters to chip designs. Comments close on November 15.
3 min read

By the numbers
- technologies in the draft export list
- 40
- of them AI technologies
- 23
- parameter threshold for covered models
- 2T
- public comment deadline
- Nov 15
China proposed on Friday, October 16, 2026, to restrict or ban the export of 40 technologies, 23 of them in artificial intelligence. The draft covers large AI models, AI agents, chip designs and computing clusters. It matters because China is home to many of the open AI models developers download today, and the rules would decide which parts of them can leave the country.
The Ministry of Commerce and the Ministry of Science and Technology published the draft jointly, the Associated Press reports. It updates China's catalog of technologies whose export is banned or needs approval. The public can comment until November 15.
What the draft covers
The list has 40 entries in total. Besides the 23 AI items, it names 12 solar technologies, including polysilicon production, and five in biomedicine, including cell and gene therapy, AP reports.
| Area | What the draft would control |
|---|---|
| Large AI models | Weights, source code and other core parts of models with at least 2 trillion parameters, or models ranked in the world's top 10 on tests such as performance and safety |
| Sensitive data | Core technologies for models trained on sensitive national data, which would be banned from export |
| AI agents | Agents built for highly sensitive settings, such as national defense and critical information infrastructure |
| AI chips | Design know-how for chips made at 14 nanometers or below, or built by stacking chips in 2.5D or 3D |
| Memory | Some memory chip designs |
| Solar and biomedicine | 12 solar and five biomedicine technologies |
A model's weights are the learned numbers that make it work. Parameters are those numbers, counted. A 2-trillion-parameter model is very large, and the threshold only reaches the biggest systems.
The size threshold and the top-10 test come from Bloomberg's reporting, as cited by The Next Web. The draft names no model. Bloomberg and AP report that Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max are both above the size limit.
What stays open
The draft carves out several kinds of use, The Next Web reports. Open-source code and published research are exempt. Chinese companies can keep serving users abroad through apps, websites and APIs, the interfaces programs use to call a model over the internet.
Running a covered model on servers outside China counts as an export. But a Chinese firm that runs one on its own overseas cloud servers could get a license automatically, according to the same report.
A temporary rule also took effect on October 16. Companies must now register before exporting any listed item, including deals that are not yet complete, The Next Web says.
Why Beijing says it is doing this
The commerce ministry called the measures "necessary" and cited national security as one reason, AP reports. Its statement said the aim is "reinforcing the security bottom line, preventing misuse and abuse, and ensuring that AI remains under human control." The ministry also said the plan does not target any country or company, according to The Next Web.
Analysts quoted by AP read it as part of a wider split. Lian Jye Su, chief analyst at research firm Omdia, said the move can be seen as a response to Western countries' sovereignty requirements on AI. "The world is getting more fragmented in trade and investment, but also in access to technologies," said Gary Ng, senior economist at Natixis.
What this means for developers
- API access should not change. The draft lets Chinese firms keep selling to overseas users through apps and APIs. Teams that call a Chinese model over the internet are the least exposed.
- Check how you host Chinese models. Running a covered model on servers abroad counts as an export. If a partner hosts a large Chinese model for you outside China, ask whether it needs a license or registration.
- Watch the open-weights wording. The reports say open-source code and published research are exempt. None of them says whether downloadable model weights count as open source. The final text will decide that, so read it before planning around the largest open models.
- Chip design work now needs paperwork. Design know-how for chips at 14 nanometers or below, or for 2.5D and 3D stacking, is on the list. Cross-border design projects with Chinese partners should expect the new registration step from October 16.
- Mark November 15. Companies with a stake can comment until then. Rules can change between a draft and the final version.
Sources
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