China's Announcement No. 48 Puts 23 AI Technologies on a Draft Export List

China's Ministry of Commerce and Ministry of Science and Technology proposed on October 16 to add 40 technologies to the country's export catalogue, 23 of them in artificial intelligence. A separate interim registration requirement took effect the same day, according to a Cloud Security Alliance research note published October 23.

The measure is Announcement No. 48 of 2026. Public comment on the draft catalogue runs until November 15, 2026. The Terminal did not retrieve the original text from mofcom.gov.cn, so every detail below comes from three secondary analyses.

What is on the list

The CSA note counts 40 proposed additions across three sectors, with 14 prohibited and 26 restricted overall.

1. AI23 technologies
2. Photovoltaics12 technologies
3. Biomedicine5 technologies

Source: Cloud Security Alliance note on MOFCOM Announcement No. 48, accessed 2026-11-02

Law firm Hogan Lovells Cadwalader lists the prohibited AI entries in a 23 October analysis. They are deep-synthesis forgery detection, AI cyber offensive capability including malicious code generation, large models trained on "Core Data", and high-performance agents for critical infrastructure, defence and core government work.

Restricted entries, which need a licence, include AI-assisted vulnerability discovery, large models trained on "Important Data", AI agent technologies, AI and storage chip design, and large-scale computing cluster technology.

The vulnerability-discovery entry sits close to work covered in Anthropic's exploit-chain disclosure, though no source ties the two.

The thresholds, and who published them

The CSA note reports numeric thresholds from the draft annex. The two law-firm analyses do not.

Item	Threshold reported by CSA
Core large-model technology	10^26 training FLOPs, or 2 trillion parameters, or a global top-10 position
Multi-agent systems	At least 60 concurrent agents
Agent planning	Chains of at least 20 subtasks
Compute clusters	Above 10,000 accelerators, interconnect at least 800 GB/s

Hogan Lovells says its article gives no numerical values for the compute, parameter or ranking thresholds. CMS, another law firm, refers only to "technical thresholds". The CSA note, citing ChinaTalk, calls the global-ranking criterion "by far the most up-for-interpretation."

Registration is already in force

Exporters must register through MOFCOM's Unified Business Platform before exporting listed technology, per the CSA note. The form asks for recipient details, destination, a description of the technology, end use and estimated value.

CMS names four triggers: transferring technology ownership abroad, licensing it for overseas use, a change of ownership or control that gives a foreign entity control, and other cases MOFCOM designates. Hogan Lovells says the registration "does not appear to involve substantive review or approval" and reads as an information-gathering tool.

What stays outside

Technology already public through open-source release or academic publication is excluded, according to all three sources, and earlier coverage of an open-weight release, Nanbeige 4.3 33B, shows what that published category looks like.CMS reports that MOFCOM treats API access, app or web use, SaaS and lightweight on-device deployment outside China as outside foundation-model technology export controls. Hogan Lovells says its article does not address API services.

A MOFCOM spokesperson said the revision "does not target any specific country, region, or entity," as quoted by CSA. CMS quotes the position that "the vast majority of AI technologies would remain freely exportable after the Revised Catalogue takes effect."

CMS says the final wording will be decisive and that no effective date for the final catalogue has been given. The comment window closes November 15, 2026.