China’s new export rule took effect on 16 October, before the list it applies to is even final. The commerce and science ministries proposed adding 40 technologies to the export control catalogue: 23 in AI, 12 in solar and 5 in biomedicine. 14 would be banned and 26 restricted. Comments are open until 15 November. Registration started immediately. Anyone transferring a listed technology abroad, including deals already underway, must register before the export proceeds. The line is drawn between the product and the know-how. Using a restricted Chinese model through an app, website or API is not a technology export. Deploying it on servers abroad is. Finished solar modules stay outside the controls. Polysilicon, wafer and cell manufacturing methods do not. Export controls are usually discussed as a US tool aimed at China. This is the same logic running the other way. Registration is not export permission. The final list and the effective date are still open.