China proposes export controls on 23 AI technologies and tightens restrictions on strategic sectors

Overview of the proposal

The Chinese government has introduced new rules that will subject 23 artificial intelligence technologies to export controls. The package includes advanced models, autonomous agents, and chip designs, as well as five biomedical technologies and twelve photovoltaic solar energy technologies, bringing the total to 40 items. Public consultation on the text ends on November 15, 2026, while a preliminary registration system for export operations has been in place since October 16.

What technologies are on the list?

The proposal defines categories of prohibition and restriction. Among the AI items, notable ones include large models with more than two trillion parameters or cutting-edge capabilities, agents designed for defense or critical infrastructure, and computing infrastructure that combines chips to process large volumes of data. Semiconductor projects and specific hardware sets for AI are also covered.

The full list comprises 40 technologies: 23 AI technologies, five biomedical technologies, and twelve photovoltaic solar energy technologies. Each category will be treated differently, with some subject to total prohibition and others to licensing restrictions.

Immediate impact on companies

Until the final revision comes into effect, companies must register each export operation involving the listed technologies, providing information on the exporter, recipient, destination country, intended use, and estimated value. The rule covers transfers of intellectual property, licenses for use abroad, and changes that place effective control of the technology in the hands of a foreign entity.

The end of the public consultation does not mean that the restrictions will already be in effect. There is no set date for the final implementation of the revised catalog.

Open technologies are exempt

The Ministry of Commerce clarified that technologies already made available to the public through open source code or scientific publications are not subject to the new rules. Providing access to a model via API, application, or cloud service is not considered, in itself, an export of the underlying technology. However, transferring a restricted technology for deployment abroad may be considered an export, with exceptions provided for scenarios such as private clouds.

Motivations behind the measure

The government claims that the goal is to prevent the misuse of sensitive technologies in areas such as digital attacks, without targeting any specific country or company. The initiative follows other instances of state intervention in the AI sector. Recently, the startup Manus announced a new round of funding after canceling an acquisition by Meta, ordered by Beijing.

For users and companies in Brazil, the announcement does not impose a general ban on Chinese applications. The scope of the rules will depend on how each operation is classified in the final version of the text.

Frequently asked questions

What did China propose for AI exports? The proposal includes 23 AI technologies in its catalog of prohibited or restricted exports, covering models, agents, chip designs, and computing infrastructure.

Are the restrictions already in effect? The final revision is still under consultation, but preliminary export registration began on October 16.

When does the public consultation end? On November 15, 2026. No date has been announced for the entry into force of the revised catalog.

Does the proposal ban all Chinese models? No. The classification depends on the characteristics of the technology, with distinct categories of prohibition and restriction.

What happens to technologies that are already open? Technologies that are already in the public domain through open source code or scientific publication are outside the scope.

Will Chinese AI applications be blocked in Brazil? The announcement does not establish such a blockade, distinguishing access to services from the transfer of technology for operation abroad.