China's commerce and science ministries have proposed adding 23 AI technologies to the export control list, including large models, agents and chip designs. The draft covers 40 items in total and introduces a temporary export registration rule effective 16 October. For companies building on Chinese models, this matters because access terms may change from open availability to licensed export.
Draft scope, thresholds and exemptions
The proposal lists 23 AI technologies alongside 12 solar items and five biomedicine items such as gene therapy. It was published on Friday, with public comments accepted until 15 November. The AI section covers large language models, AI agents, chip designs and computing clusters. A separate temporary rule now requires firms to register before exporting any listed item, including deals that are not yet complete.
For large models, controls would cover weights, source code and other core parts. The threshold applies to models with at least 2 trillion parameters or ranking in the global top 10 on tests such as performance and safety. According to Bloomberg, Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max exceed that size, although the draft itself names no model. Running a covered model on servers abroad would count as an export.
The draft also limits design know-how for AI chips made at 14 nanometres or below, or built by stacking chips in 2.5D or 3D. Some memory chip designs are included as well. Open-source code and published research would be exempt from the curbs. Chinese firms could continue serving foreign users through apps, websites and APIs, and firms running a covered model on their own cloud servers abroad could receive a licence automatically.
What export licensing means for AI buyers
For businesses using Chinese models via apps or APIs, continuity looks more protected than direct transfer of weights and code. A small company that embeds Qwen or Kimi through an API may see little operational change if the provider holds the export permission. A large enterprise that planned to self-host a covered model abroad or fine-tune its source code would face a licensing step and longer procurement timelines.
The main limitation is that the document is a draft open for comment until 15 November, so final thresholds and procedures can still shift. It is also unclear how automatic licensing for own cloud servers abroad will work in practice and how long approvals will take. This news alone does not mean a ban on foreign use, and the ministry said the plan does not target any country or firm. Buyers should ask vendors which delivery model is used and who handles export compliance.
The marker to watch is the final version after the comment period and the first licensing decisions under the temporary registration rule. If API access remains outside the permit process while weight transfers require approval, the market will split between hosted use and controlled technology transfer. That outcome will shape vendor choice for projects that depend on Chinese large models and chip designs.
