The Substance of the Proposal

On 16 October 2026, China's Ministry of Commerce proposed adding 40 technologies in artificial intelligence (AI), biomedicine, and photovoltaics to its catalogue of technologies prohibited or restricted from export. The announcement was made on Friday, 16 October 2026, as reported by Reuters.

This is about updating the existing catalogue: the ministry has initiated its review. The catalogue is an official list regulating technology exports: listed technologies are either fully prohibited from export or transferred under certain restrictions. Under the proposal, 14 of the 40 technologies would join the fully prohibited list, with the remaining 26 on the restricted list.

Public comments on the proposal will be accepted until 15 November 2026. At the same time, China is introducing an interim pre-export registration procedure for the relevant technologies.

It is important to note: this is not yet a decision in force, but a proposal at the public-consultation stage. Although it covers three sectors, AI is at its center: 23 of the 40 technologies belong to this field.

23 AI Areas: What Made the List

AI-related technologies — 23 of them — make up the largest part of the proposal. According to The Wall Street Journal, the list includes four main areas: large language models (LLMs), AI agents, chip design, and computing clusters.

LLMs are the class of models underlying AI systems that can understand and generate text. AI agents are systems designed to independently carry out assigned tasks. Chip design and computing clusters concern the hardware and computing infrastructure needed to build and run such models.

The list thus spans the entire AI chain — from model architecture to the capacity for training them. Together, these four areas form the key layers of the AI ecosystem: model creation (LLMs), systems built on them (AI agents), hardware design (chips), and computing capacity (clusters). The 23 areas account for more than half of the 40 technologies.

The remaining 17 technologies concern biomedicine and photovoltaics. Biomedicine is the complex of technologies in medicine and biology; photovoltaics is the field of technologies for converting sunlight into electricity.

Scope: What Is Covered, What Is Excluded

The proposal would also cover overseas deployment of AI models containing restricted technology — that is, running such models on servers outside China or installing them into local infrastructure would also be regulated.

At the same time, the ministry clarified an important exclusion: access via APIs, websites, apps, and SaaS (software-as-a-service) platforms does not fall under this regime. An API is developers' programmatic access to a model through an interface; SaaS means using a ready-made service through a browser or app.

This exclusion defines the proposal's practical boundaries. The restrictions target the transfer of technologies abroad; ordinary use of ready-made AI services stays outside their scope. Foreign developers connecting to Chinese AI models via API or ordinary users accessing them through apps would therefore not fall under the proposal. Since API and SaaS access is excluded, the proposal does not directly affect everyday use of AI services.

The Ministry's Comment

In a separate statement, the ministry said the catalogue review was proposed because applications of the relevant technologies in sensitive fields are constantly expanding. According to the statement, it is precisely this circumstance — the expanding scope of technology applications — that necessitated the catalogue update. The ministry stressed that the move is routine in nature and does not target any specific country, region, or entity. The phrase "does not target any specific country, region or entity" means exactly this — the step aims to update the general regime, not to single out a target.

"The move was routine and does not target any specific country, region or entity," the Chinese Ministry of Commerce said in its statement.

Next Steps

Public consultation on the proposal runs until 15 November 2026. During this period, any interested party that has reviewed the proposal text can share their views — which is precisely why the ministry is seeking public comment.

During the consultation period, the relevant technologies are covered by the interim pre-export registration procedure — a measure of an interim nature. The registration procedure applies for the duration of the consultation — something the ministry announced at the same time as the proposal.