China Proposes Export Curbs on 23 AI Technologies to Retain Domestic Advantages

China has proposed adding 23 AI-related technologies to a list that bans or restricts technology exports. The additions include advanced models, agents capable of acting with limited human direction, chip-design technology and technology for operating large computing facilities. The proposals would promote a business model that keeps valuable technology in China while providing foreign customers with access, amid intensifying competition with the United States.

The draft, published on October 16, separates foreign use of Chinese AI services from foreign acquisition of models, data or expertise for independent operation or reproduction. Overseas customers would generally retain access through websites and cloud platforms. However, some transfers of underlying technology and some overseas deployments would require government approval. A temporary registration requirement for certain transfers took effect immediately.

A source familiar with discussions said China is expected to adopt the proposals by the end of the year and provide implementation guidance afterward. The source requested anonymity because the schedule was not public. Public consultation ends on November 15. China's commerce ministry did not respond to a request for comment.

The proposals could affect how leading Chinese AI developers operate advanced models in overseas data centres, arrange international partnerships and manage foreign investment or ownership of AI assets. DeepSeek, Moonshot and Z.AI provide overseas customers with models through websites or cloud platforms. Some developers also use computing facilities abroad to obtain access to advanced chips subject to US export restrictions on China. US restrictions prohibit exports of Nvidia's most advanced processors to China.

A person briefed on the matter said researchers at major Chinese AI laboratories want clarification about training or running advanced models on foreign-owned servers overseas. The person requested anonymity because the discussions were private. The person said the worst-case outcome could require developers to maintain different domestic and overseas versions of the same downloadable model. Liu Jing, a senior partner at Beijing Dacheng Law Offices who joined consultations with policymakers, said companies also wanted clearer criteria for determining model coverage.

The draft sets a training-computation threshold of 10 to the power of 26 calculations. Another test covers models with at least 2 trillion parameters, the numerical settings learned during training. A further test covers models ranked among the world's top 10 in specified assessments of performance, usage or efficiency. The ranking criterion could include smaller models that perform particularly well on specialised tasks, but the draft does not specify eligible rankings.

Law firm Han Kun questioned how regulators would measure models that use only part of their components for each task. Han Kun also said a proposed chip-design provision could cover products beyond the most advanced chips because the provision contains no minimum performance threshold.

Law firm Fangda said registration requirements effective from October 16 cover transfers that place Chinese technology under foreign ownership or control. Fangda said qualifying transactions already in progress are also covered. Earlier this year, Beijing ordered Meta to reverse the acquisition of Chinese-founded AI startup Manus for more than $2 billion, demonstrating risks for foreign buyers.

Han Kun said the draft offers simplified approvals when Chinese companies build and operate computing facilities abroad. However, Han Kun said the draft does not expressly offer the same treatment for technology transfers enabling foreign customers to construct equivalent facilities. The controls also encompass techniques for coordinating more than 10,000 AI chips.

Alfredo Montufar-Helu, Ankura's Beijing-based managing director, said the market was already moving toward the leadership's preferred arrangement: retaining intellectual property and research in China while selling operations and access overseas. Montufar-Helu said commercial efforts to preserve technological advantages accompany security concerns, including retaining sensitive data and powerful cyberattack capabilities in China. Yang Jingru, a partner at Jincheng Tongda & Neal, described the approach as a counterpart to US technology and investment restrictions. Yang wrote that the United States controls incoming computing power, hardware and capital, while China is starting to manage outgoing models and technological assets systematically.