China is revising its technology export-control catalogue and has invited public consultation on proposed changes, including technical indicators, control policies, and facilitative measures. The proposed revisions, announced on Oct. 16, cover 40 technologies, 23 of which are linked to AI.
The Chinese Ministry of Commerce said in a public policy document released on Friday (Oct. 15) that the revisions to the export-control catalogue are important for securing China’s critical information sinfrastructure, defence industries, and sensitive government systems.
AI has become a critical component of Chinese exports, which rose 36.3 percent year-on-year in September, according to Caixin Global , a Beijing-based Chinese media outlet. This further underscores AI’s growing strategic importance to China’s economy and cybersecurity.
Technologies proposed for export control under the Catalogue of Technologies Prohibited or Restricted from Export by China include AI models built on China’s core data. This refers to “data concerning national security, the lifeline of the national economy, key public livelihoods and major public interests,” according to the Taipei Times .
“In accordance with the Foreign Trade Law of the People’s Republic of China and the Regulations on the Administration of the Import and Export of Technologies of the People’s Republic of China, the Ministry of Commerce and the Ministry of Science and Technology plan to revise the Catalogue of Technologies Prohibited or Restricted from Export by China by adding certain technologies in artificial intelligence (AI), biomedicine, and photovoltaics,” the Ministry said in another release .
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In a separate release outlining the proposed revisions, the Ministry cited examples related to cybersecurity, including “AI-driven malicious-code generation and mutation” and “AI-assisted vulnerability discovery.”
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“AI-driven malicious-code generation and mutation” involves using AI to generate malicious software code or modify existing malicious code to make it harder to detect. Such techniques can increase the speed and volume of cyberattacks, including those targeting government networks, defense systems, and critical infrastructure.
“AI-assisted vulnerability discovery” refers to the use of AI to identify flaws in software, networks, applications, or computer systems that attackers could exploit. It is an important component of cybersecurity.
“The Chinese government’s necessary management of these technologies aims to solidify the security baseline, prevent misuse and abuse, ensure that AI remains under human control, and promote international governance of AI,” a spokesperson said in a statement, according to the Taipei Times .
The Ministry of Commerce said on its website that the proposed revisions were part of its “routine management of technology trade” and were not specifically directed at any country, region, or entity.
“Technologies that have already entered the public domain through open-source releases, academic publications, and similar means will be excluded from the scope of management,” the Ministry said.
Impact on global AI industry
Experts told media outlets around the world that China’s revisions to its technology export-control catalogue are a response to Western restrictions on AI technology exports. They warned that China’s proposed curbs could add to the uncertainty facing the global AI ecosystem.
The global AI industry faces mounting pressure from strict content controls imposed by several governments and key technology producers. According to the Taipei Times , the revisions proposed by the Chinese government will add to the uncertainty facing the global AI ecosystem.
Several Western nations have introduced restrictions on AI-related technology exports, including advanced semiconductor chips, chipmaking equipment, computing infrastructure, and certain AI model technologies. Notable restrictions have come from the United States, which has restricted exports to China of certain advanced computing chips, including high-performance accelerators used to train and run frontier AI models.
The Netherlands, which plays a strategically important role in the AI ecosystem because ASML supplies advanced lithography equipment, also introduced export authorisation requirements for additional types of advanced semiconductor-manufacturing equipment effective April 1, 2025. Japan, meanwhile, has imposed export controls on 23 categories of semiconductor-manufacturing equipment since 2023.
Leonhard Xu, a senior consultant at Berlin-based consultancy Sinolytics, told The National that the announcement was “extremely expansive” and that a detailed assessment would take time. He also emphasised that export controls do not necessarily amount to an export ban.
The Associated Press (AP) reported that the proposed revisions to the technology export-control catalogue did not specify particular AI models. However, AI models with “parameter counts” of 2 trillion or more, or those with “certain world-leading capabilities,” could be included in the list by China’s Ministry of Commerce. A model’s parameter count refers to the number of adjustable values it uses to learn patterns from data.
Lian Jye Su, chief analyst at technology research and advisory group Omdia, told AP that China’s proposed revisions to the technology export-control catalogue “can be seen as a response to Western countries imposing sovereignty requirements on AI, robotics, telecommunications, and other key technologies.”
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