40 Technologies Proposed for Export Control

On October 16, 2026, China issued MOFCOM and MOST Announcement No. 48, proposing to add 40 key technologies across artificial intelligence, photovoltaic, and biopharmaceutical sectors to the Catalogue of Technologies Prohibited or Restricted from Export. Public comment runs through November 15, and pre-export registration for the listed technologies takes effect from the announcement date. This round redraws both the boundaries and the timing of technology export. This article first breaks down the 40 items, then explains what they actually mean for exporters going global.

The 40 Technologies at a Glance: What Each Sector Controls

The proposed additions total 40 items, split into 14 proposed for prohibition and 26 proposed for restriction. By sector: 23 in artificial intelligence, 12 in photovoltaics, and 5 in biopharmaceuticals. The exact prohibited and restricted allocation by sector follows the annex list of the announcement; most entries already specify concrete technical parameters.

One point easily missed: the scope of the 12 PV items covers not only processes but also the core and key equipment that embodies the underlying technology. In other words, certain equipment itself may also fall under control.

2. Our View: What This Means for Exporters

This round controls the transfer of technology from within China to outside China, not the export of goods. Transferring technology ownership overseas, licensing China-based technology for overseas use, and shifting control of China-based technology to an overseas entity all trigger registration. Many factories assume only selling equipment is covered, but in fact technology licensing, joint ventures, and changes in overseas subsidiary shareholding all count.

Among the 23 AI items, what is truly locked down is the core of large models trained on sensitive state-key data and AI agents serving critical information infrastructure. The vast majority of AI technologies remain freely exportable. Open source, API calls, SaaS, app or web interaction, and on-device lightweight deployment, the common going-global formats, are explicitly outside scope. Do not be scared by the headline number "40".

Pre-export registration is an immediately effective interim measure, the most easily overlooked point. Public comment runs to November 15, but registration must begin from October 16, and technology exports already started but not yet completed must also be retroactively registered. The comment period and the registration effective date are two separate timelines; do not conflate them.

Within the 12 PV items, perovskite and tandem cells go into the prohibited category while HJT goes into the restricted category, exactly the areas where China holds globally leading advantages. This shows the control logic is to protect leading technologies, not a blanket restriction. PV exporters should re-evaluate which technology collaborations and equipment packages might cross the line.

3. Three Recommendations for Manufacturers

ü Factories involved in AI, PV, or biopharma R&D should immediately go through the annex list item by item to confirm whether their technology, process, or even core equipment falls within scope. The list is metric based, with most items specifying concrete technical parameters, so the comparison is straightforward.

ü Whenever there is any plan to transfer, license, or change control of technology to an overseas party, treat pre-export registration as a required step and register on MOFCOM unified business system platform (ecomp.mofcom.gov.cn). Do not wait until the contract is signed to discover you need retroactive registration, which could derail the closing.

ü Distinguish what is controlled from what is not. Open-source technology, API, SaaS, and app deployment, and overseas self-hosted cloud deployment eligible for automatic licensing, are either outside restriction or on a fast-track channel. In designing your going-global model, prioritize these forms where possible for lower compliance cost.

4. Frequently Asked Questions

Q: A factory making AI products puts the model into an app for overseas app stores. Does it need registration?

A: Providing API calls, app or web interaction, SaaS applications, or local on-device lightweight deployment using a restricted large model is not within the scope of large-model technology export control and does not require registration under this rule. But if you transfer the model core weights or training methods overseas as a whole, it does.

Q: We already signed an overseas technology licensing contract that is not yet fully performed. What should we do?

A: The announcement explicitly states that exports already started but not yet completed are also within the registration scope. You should retroactively register on the platform above to avoid obstacles in later closing.

Q: Is submitting comments during the consultation period useful?

A: Yes. Before November 15, you may submit by email, fax, or letter on the newly added technology scope, metrics, control policy, and facilitation measures. The final catalogue may be adjusted accordingly.

Conclusion: This round of export control adjustment is not a blanket tightening, but a precise move to protect leading technologies and to draw clear lines on the timing and boundaries of technology export. For exporters going global, the core actions are three: self-check against the list, register what should be registered first, and prioritize fast-track channels where available.

Sources: MOFCOM and MOST Announcement No. 48 of 2026, Public Consultation on Revision of the Catalogue of Technologies Prohibited or Restricted from Export and Interim Registration Management of Related Technology Exports; Global Times (English edition), Economic Daily, and Guangming Daily reports. The composition of the 40 items, the 14 prohibited and 26 restricted, the three-sector breakdown, the pre-export registration timeline, and the exemptions and facilitation measures are all drawn from the official announcement and the reports above.