China Proposes Export Controls on 23 AI Technologies Amid US-China Rivalry

China Proposes Sweeping AI Export Controls

China's commerce ministry and Ministry of Science and Technology jointly published a draft proposal on Friday adding 23 AI technologies to the country's export control list1

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. The China AI export controls cover AI models and agents, chip designs, computing clusters, model weights, and source code, citing national security concerns amid escalating geopolitical rivalry with the U.S.4

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. The proposals form part of a broader revision of China's technology export catalogue, covering 40 technologies across AI technology, biotechnology, and solar power3

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Export Restrictions Target Advanced AI Models

The proposed controls would restrict exports of large models with parameter counts of 2 trillion or above, or those ranking in the world's top 10 on performance and safety benchmarks4

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. Chinese AI models including Moonshot's Kimi K3 and Alibaba's Qwen 3.8-Max exceed the 2 trillion parameter threshold4

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. The controls would cover overseas deployment of AI models containing restricted technology, including weights and source code, but crucially exclude API access through websites, apps, and software-as-a-service platforms3

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. This distinction allows Chinese AI developers such as DeepSeek and Alibaba to continue expanding internationally while giving Beijing greater oversight of sensitive technology transfers abroad3

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Chip Designs and Computing Infrastructure Under Scrutiny

The draft proposal includes export restrictions on chip designs for AI processing chips and memory chips made at 14 nanometres or below, or built using 2.5D or 3D chip stacking technology5

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. Computing clusters also fall under the proposed controls, though Chinese firms running covered models on their own cloud servers abroad could receive automatic licensing5

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. The commerce ministry emphasized the controls aim to prevent misuse of AI technologies, particularly systems capable of autonomously generating and modifying malicious software that could threaten critical infrastructure3

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Open-Source Technology Remains Exempt

Despite the sweeping nature of the proposed controls, technology already in the public domain through open-source releases or academic papers would remain outside the restrictions3

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. The commerce ministry stated most AI technologies would remain freely exportable, with simplified licensing for open-source technology exports3

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. This approach preserves API access for individual users, allowing Chinese AI tools to continue growing in popularity overseas while maintaining sovereignty requirements on core technology transfers2

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Rising Chinese AI Models Drive Policy Response

Chinese models have experienced rapid growth in recent months, with DeepSeek V4.1 Flash and Step 5 Preview burning through more than 50 trillion tokens compared to Anthropic's Claude Opus model at 5.85 trillion tokens2

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. Chinese AI models have gained ground internationally on lower prices and improving capabilities since DeepSeek's R1 model emerged early last year, raising the stakes for Beijing as it decides how tightly to guard the sector3

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. Reuters reported in July that Chinese authorities had discussed with major technology companies, including Alibaba, ByteDance, and Z.AI, potentially restricting overseas access to China's most advanced AI models3

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US-China Rivalry Shapes Export Control Landscape

The proposal emerges as an ironic reversal of the US-China rivalry dynamic, with China now restricting access to its own AI tools after years of Western developers and the White House complaining about Chinese developers copying their technology2

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. Washington's export controls on China's access to cutting-edge American AI chips needed to train frontier models have helped keep US firms Anthropic and OpenAI in the lead, though Chinese rivals are finding workarounds to narrow the gap3

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. Gary Ng, senior economist at Natixis, noted that AI is increasingly strategic for both China and the U.S., with the world becoming more fragmented in trade, investment, and technology access4

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Bilateral Cooperation Continues Despite Competition

Despite the competitive atmosphere, bilateral efforts are underway to address existential risks posed by AI technology2

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. President Trump and Chinese Premier Xi Jinping agreed during a September meeting that humans should remain in control of nuclear weapons decisions2

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. The two powers established an AI-hotline-style dialogue and incident-communications channel for advanced AI to provide early warning should rogue AI conduct unplanned operations2

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Implementation Timeline and Industry Impact

Exporters must register certain overseas technology transfers starting Friday, pending final rules after public consultation on the proposals closes November 153

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. The temporary export registration rule took effect on October 16 and also covers deals not yet complete5

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. With these controls in place, Chinese companies would be able to license these technologies but not sell the intellectual property overseas2

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. The capabilities of frontier models like Anthropic's Mythos have highlighted the potential for AI to turbocharge cyberattacks, worrying Beijing and prompting Chinese companies to develop their own versions3

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