The commerce and science ministries have proposed new China technology export controls covering 40 AI, biopharma, and solar technologies. While generous exemptions in AI and biopharma soften the impact of the curbs on international collaboration, the limited carve-outs in solar mean foreign manufacturers may face significant sourcing risks.
On 16 October 2026, China’s Ministry of Commerce (MOFCOM) and Ministry of Science and Technology (MOST) released a draft amendment to the Catalogue of Technology Prohibited or Restricted for Export, prohibiting or restricting the export of 40 different AI, biopharma, and solar cell technologies. Companies will not be able to export items on the prohibited list and will need to apply for licensing to export items on the restricted list.
MOFCOM is soliciting public feedback on the amendment until 15 November 2026.
The proposed draft is the latest effort to shore up national security in sensitive technology sectors while protecting core economic and commercial interests in frontier technologies.
Get Sourcing Support
While the draft amendment has not yet been adopted, companies exporting affected technologies are required to carry out pre-export registration with MOFCOM in the interim.
In an effort to maintain international collaboration and global expansion in these key areas, the announcement also provided generous carve-outs and streamlined licensing procedures for certain application scenarios. For instance, products manufactured using the restricted technologies will not be subject to the restrictions, while AI technologies that have already entered the public domain will be exempted.
As a result, the restrictions are expected to have a limited impact on technology exports in AI and biopharma. However, exemptions in the solar field are limited, and restrictions on core technologies for frontier solar panels mean the curbs could stymie the development of these technologies overseas.
Which technologies are subject to export curbs?
AI technology exports
A total of 23 technologies are listed under the AI category. The prohibited technologies are generally those that could pose a significant risk to China’s national security should they end up in the hands of malicious actors. For instance, the prohibited technologies include large-scale models trained on “core data” (broadly, data related to China’s national security, economy, public well-being, and public interest and intelligent agents designed or primarily intended for use in highly sensitive environments (such as national critical information infrastructure (CII), national defence, or core government operations).
Meanwhile, the restricted technologies tend to cover AI technologies that pose a lower national security risk but for which China has key economic and commercial interests, such as frontier models and their underlying hardware. They include core technologies for large-scale models, such as weights and underlying source code, that meet certain requirements, including high computing power and 2 trillion or more parameters, as well as “capabilities that reach a globally leading level”. Several of China’s leading AI models that are of strategic commercial importance, including Alibaba’s 2.4-trillion-parameter Qwen3.8-Max model, fall within this scope.
Other restricted items include large-scale models trained on “important data” – a data category that falls below “core data” risk level but is also subject to various protection and data export requirements under China’s data laws.
Exemptions
Technologies that have already entered the public domain through open-source releases or academic publications are exempted. MOFCOM also intends to allow automatic licensing for the export of AI technologies for open-source releases, the operation of overseas data centres by Chinese companies (or deployment of AI on a company’s own cloud infrastructure abroad), overseas chip fabrication, joint R&D using foreign resources, and participation in the formulation of international standards.
The provision of API access, app/web-based interactions, SaaS applications, or lightweight, on-device deployments of AI using restricted large-scale models are exempted.
Biopharma technology exports
The biopharma categories include five technologies related to cell and gene therapy, small nucleic acid drugs, and pathogenic microorganisms. The existing list already includes pharmaceutical and biomedical items, and the expansion reflects China’s growing strength in the field and the potential national security risks this poses, as well as the industry’s growing commercial importance.
Prohibited technologies include proprietary technology and process platforms for cell and gene therapies and small interfering RNA (siRNA) drugs, where the entity holds independent IP rights.
Restricted items include proprietary technologies for the discovery and validation of novel therapeutic targets for cell and gene therapy and small siRNA, where the entity holds independent IP rights.
Exemptions
As with the AI fields, the announcement provides various exemptions designed to enable external collaboration in key technologies. For instance, the prohibition on export of proprietary technology and process platforms for cell and gene therapies and siRNA drugs applies only where there is a transfer of ownership, not to arrangements such as licensing or the provision of outsourced R&D and manufacturing services using these technologies and processes. For specific drug products at various stages of R&D or manufacturing, the use of relevant technologies and processes for external collaboration or business development is exempted if they are necessary for processes such as R&D and testing.
Meanwhile, MOFCOM will enable automatic licensing for outbound licensing models that do not involve the transfer of ownership.
Automatic licensing may also be applied to public health emergencies, humanitarian aid, or joint R&D efforts that utilize overseas resources.
Proposed restrictions on solar technology exports
12 solar cell technologies are prohibited or restricted, including those related to the manufacturing of polysilicon, silicon wafers, and solar cells, with restrictions extending to the key and core equipment that embodies these technologies.
Prohibited items include certain polysilicon production technologies, preparation technology for ≤70 μm silicon wafers, and solar cell fabrication technologies, including for the production of perovskite and tandem solar cell modules and the manufacturing technologies for associated equipment. Perovskite and tandem solar cells are cutting-edge photovoltaic (PV) technologies that are in early stages of commercialisation, for which China therefore has significant strategic interest.
Restricted items include technology for pulling monocrystalline silicon ingots for PV applications, manufacturing technologies and associated equipment for high-efficiency Tunnel Oxide Passivated Contact (TOPCon) and back-contact (XBC) crystalline silicon solar cells (advanced designs of silicon solar cells).
The MOFCOM spokesperson noted that the new restrictions were necessary in light of the expansion of solar technology into more sensitive sectors, such as aerospace, national defense, unmanned systems, and high-security infrastructure, thus posing a national security risk.
Exemptions
Unlike AI and biopharma, the exemptions for solar technologies are relatively limited; MOFCOM only notes that the PV equipment included in the list is subject to the restrictions only if it is used to produce restricted technologies.
What this means for China sourcing
At this point in time, the anticipated impact on the export of these technologies for the fields of AI and biopharma is relatively limited, given the scope of exemptions provided.
For AI, the exemption granted to technologies in the public domain, as well as open-weight models hosted on Chinese companies’ own overseas data centres and cloud platforms, means that many Chinese AI models will not be affected by the export curbs. This is because, in contrast to the US’s closed frontier models, Chinese companies have overwhelmingly adopted an open-weight approach for AI development.
Speak to an Adviser
However, Chinese AI developers are increasingly releasing proprietary models to generate additional revenue, which may fall under the restrictions. As the industry develops in this direction, the export curbs may become more material.
For biopharma, the carve-outs for licensing mean that foreign companies will still be able to source necessary technologies from China, even though outright acquisition may no longer be possible. However, limitations to licensing arrangements could hamper certain operations, and companies licensing the affected technology should ensure that the license allows the operations and applications for which it is intended.
The restrictions on solar technologies are likely to have the biggest impact on companies outside of China, given China’s dominance in both production and frontier technology, and the limited exemptions provided. The curbs may therefore stymie efforts by countries to develop their domestic solar manufacturing capabilities, adding to technology bottlenecks and slowing down certain manufacturing processes as companies may need to look for suppliers in other countries. The prohibitions on technologies for the production of perovskite and tandem solar cells in particular could impact foreign companies’ ability to bring the most advanced solar cells to market.
As the restrictions apply only to technologies used for the manufacture of solar products, not the products themselves, they will not impact companies’ ability to source material inputs from China.
How Dezan Shira & Associates can help
China’s proposed export curbs on AI, biopharma, and solar technologies may add a new risk to technology sourcing. Dezan Shira & Associates provides supply chain and tariff advisory to help businesses assess their exposure, strengthen supplier due diligence, and plan continuity, including diversification into Vietnam, India, or ASEAN. Contact us to discuss how these curbs may affect your China sourcing strategy.
