China introduces export controls on large AI models and chip designs

China’s commerce and science ministries issued a draft that would add 23 artificial‑intelligence technologies—large language models, agents, chip designs and compute clusters—to the country’s export‑control list, while also listing 12 solar‑related items and five biomedicine items. The temporary registration rule went into effect on 16 October and applies to any deal that has not yet closed. The draft covers 40 items in total, and open‑source code and published research are exempt so firms can continue serving overseas users through apps and APIs.

Large Model Restrictions

The draft sets a 2‑trillion‑parameter threshold for large models, requiring companies to seek a licence before open‑source releases of models that size or that rank in the top 10 on performance or safety tests. Models such as Moonshot AI’s Kimi K3 (2.8 trillion) and Alibaba’s Qwen3.8‑Max (2.4 trillion) fall into this category. A streamlined automatic licensing pipeline is said to be in place, but the rules add a risk premium that could delay new launches.

Export controls also cover design know‑how for AI chips made at 14 nanometres or smaller, or built using stacking techniques, and some memory‑chip designs are listed. While Chinese firms can keep serving users abroad via their own cloud, running a covered model on foreign servers counts as an export. The move follows earlier talks and coincides with Taiwan’s new criminalisation of smuggling advanced chips to China under a US‑backed trade agreement.