# China Begins Temporary Export Registration for 40 Technologies

By Riza Dagoc

Canonical URL: https://www.tokenpost.com/news/regulation/40490
Published: 2026-10-25T11:31:53.000Z
Updated: 2026-10-25T11:31:53.000Z
Section: Regulation

> The proposal covers 23 AI technologies. Remote access through an API, app, website or SaaS product is not treated as a technology export.

China’s Ministry of Commerce and Ministry of Science and Technology began temporary pre-export registration for covered technology transfers on Oct. 16, as they proposed adding 40 technologies to the country’s export-control catalog. The ministries also clarified that providing AI services remotely to overseas users does not itself count as exporting the underlying technology.

The proposed additions span artificial intelligence, biopharma and photovoltaic technologies. AI accounts for 23 of the 40 entries. Across all three fields, 14 technologies are proposed for prohibition and 26 for restriction; the overall figures do not specify how many AI entries fall into each category.

The temporary filing requirement applies to transfers of technology ownership, licenses allowing overseas use, and cases where a technology’s owner or actual controller becomes an overseas entity. Transfers already underway but not completed are also covered. The requirement falls on the technology exporter in China, rather than on overseas users who access a service.

Filings must include basic information about the exporter and recipient, the destination, the technology’s content and intended use, and the expected export value. The temporary measure is due to remain in place until the revised catalog takes effect.

For AI, access through an API, app, website or software-as-a-service product is not treated as a technology export, including when the service uses a restricted large model. Overseas local deployment of restricted technology remains subject to export management. Deployment on a company’s own overseas cloud may qualify for automatic licensing.

Technologies already in the public domain through open-source releases or academic papers are proposed for exclusion from management. Certain AI technology exports for open-source releases can receive automatic licenses. The general service-access rule does not determine whether a particular DeepSeek or MiniMax model is covered by registration. It remains unclear whether the newly released DeepSeek V4.1-Flash-1017 and MiniMax M3.1 Flash models were covered by registration.

The draft remains open for public comment through Nov. 15. The final catalog and the date it will take effect have not been set.