China Proposes Export Controls on Its Top AI Models and Chip Designs
3 min readChina has spent three years on the receiving end of technology export controls. On Friday it drafted its own. The Ministry of Commerce and the Ministry of Science and Technology jointly published a proposed update to China’s catalog of restricted and prohibited technology exports that adds 40 items, 23 of them in artificial intelligence. The China AI export controls would cover large models, AI agents, chip design know-how and computing cluster architecture, and the public has until November 15 to comment.
What the draft covers
The headline threshold is scale. According to The Next Web and Bloomberg, exports of model weights, source code and other core components would need a license for any model with at least 2 trillion parameters, or any model ranked in the world’s top ten on performance or safety benchmarks. Moonshot’s Kimi K3 and Alibaba’s Qwen 3.8-Max are reported to clear that bar, although the draft names no companies. Models trained on sensitive national data, and agents built for defense or critical infrastructure, would be barred from export outright.
Chip design is in scope too: methods for chips at 14 nanometres or below, 2.5D and 3D stacking, and some memory designs. A temporary registration rule took effect the same day, and it reaches deals that are already under way but not yet complete.
The carve-outs matter as much as the rules. Open-source code and published research are exempt, and Chinese firms can keep serving foreign customers through apps, websites and APIs. Running a covered model on servers abroad counts as an export, but companies hosting it on their own overseas cloud could get a license automatically. A ministry spokesperson said the aim is to prevent misuse and keep AI under human control, and that the plan targets no country or company, according to the Associated Press.
Why it matters
For the past year the open-weight story in AI has largely been a Chinese story. DeepSeek, Qwen, Kimi and GLM releases set the pace for everyone outside the big US labs, and Beijing’s UN ambassador recently claimed 10 billion downloads of Chinese open models. This draft does not end that, since anything already published stays exempt, but it puts a licensing gate in front of the next frontier release and makes the weights themselves a controlled good.
It also mirrors Washington. The US has restricted chips and chipmaking tools since 2022 and briefly asked Anthropic to wall off its top models from foreign nationals in June. Omdia’s Lian Jye Su reads Beijing’s move as a response to Western sovereignty demands, and Natixis economist Gary Ng called it one more sign that access to technology is fragmenting along the same lines as trade.
Watch the thresholds. Two trillion parameters and a top-ten ranking are moving targets, and how the ministries define them will decide whether this is a narrow gate or a wide one.