Akin Gump·SANCTIONS / EXPORT CONTROLS

China Tightens Export Controls on AI, Biomedicine, PV Tech and Dual-Use Items

MOFCOM's October 2026 package proposes 40 new AI, biomedicine and photovoltaic technology control parameters, revises UAV, tunnel-boring-machine and dredger dual-use controls effective November 18, and adds customs inquiry deadlines.

Between October 13 and 19, 2026, MOFCOM issued a package that materially tightens China's export control regime. Announcement No. 48, with MOST, proposes adding 40 technology control parameters (23 AI, five biomedicine, 12 photovoltaic) to the Catalogue of Technologies Prohibited or Restricted from Export, comments due November 15, 2026, and already requires exporters to register exports of the listed technologies pending the revised Catalogue. Restricted AI parameters reach large models trained on "important data," core model elements above stated compute and parameter thresholds, AI agent and chip design technologies, and cluster interconnect technologies above 10,000 accelerators; prohibited parameters cover models trained on "core data." Announcements Nos. 49-51 revise dual-use controls on UAVs (endurance threshold raised from one to three hours), tunnel boring machines and dredgers, effective November 18, 2026, and draft civil aviation measures would replace individual licensing with a 60-day "export certificate." Announcement No. 52 creates a MOFCOM referral role, 15-plus-15 working-day review clocks, and expressly extends inquiry procedures to e-commerce, traveler and express shipments. Counsel should note that the interim registration duty is live while the scope of controlled technologies and registrable activities — including joint R&D, design-file sharing and overseas model deployment — remains unsettled; watch the comment deadlines and the final Catalogue.

china-export-controlsdual-use-itemsmofcomai-chip-controlsuav-controlsbiotech-export-licensingphotovoltaic-export-controlscustoms-enforcement
Read the original firm alert → Saturday, October 31, 2026

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