China’s October 16 technology export notice
The consultation concerns 40 technologies, but the announcement also creates a distinct temporary filing requirement.
What the announcement does
MOFCOM and MOST published Announcement No. 48 on October 16, 2026. The proposed revisions would add 23 AI, five biomedical, and 12 photovoltaic technologies to the prohibited or restricted technology export catalogue. MOFCOM’s Q&A describes 14 proposed prohibitions and 26 proposed restrictions. Public comments are accepted through November 15, 2026. Announcement 48 Official Q&A
What already applies
The notice separately requires pre-export registration for listed technologies from its publication until the revised catalogue enters into effect. The requirement addresses specified transfers of ownership, licensing for use abroad, and certain changes of ownership or actual control to a foreign party; transactions already started but not completed can fall within it. Original notice, section III
Scope limits
The agency states that already-public AI technologies disclosed through open source or academic publication are outside the proposed management scope. Its Q&A distinguishes restricted technology transfer from mere API, app, web, SaaS, or lightweight local model access. Those distinctions are source-specific and must be checked against the draft annex. Agency explanation