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# China proposes export controls on 23 AI technologies, including its largest models and chip designs

**[Collections](https://daily.dev/sources/collections)** · 2 min read · 4 upvotes · 1 comments

## Summary

China's commerce and science ministries have proposed adding 23 AI technologies to its export control list, mirroring US chip restrictions. The draft targets large language models above 2 trillion parameters or ranked top 10 on performance/safety benchmarks, AI agents, computing clusters, and chip designs at 14nm or below. Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max reportedly fall within the size threshold, though the draft names no specific models. Open-source code and published research remain exempt, and Chinese firms can still serve overseas users via apps, websites, and APIs — the restriction targets shipping the technology itself, not foreign usage. A temporary export registration rule took effect October 16, requiring firms to register before exporting listed items; public comments on the draft are open until November 15. The benchmark-ranking clause is notable since a shifting top-10 list could pull more models into scope as new ones are released.

## Content

China's commerce and science ministries have proposed adding 23 AI technologies to the country's export control list. The draft revision to the catalogue of technologies prohibited or restricted from export also covers biomedicine and solar power. Public comments are open until 15 November.

## What the draft covers

The AI items include:

- large language models above 2 trillion parameters, or ranked in the top 10 on performance or safety benchmarks
- AI agents
- computing clusters
- chip designs for chips at 14nm or below

The draft names no specific models. Reports say Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max fall within the size threshold.

Open-source code and published research are exempt, and Chinese firms can keep serving overseas users through apps, websites, and APIs.

## Registration is already in force

A temporary export registration rule took effect on 16 October. Firms must register before exporting listed items, including incomplete deals. According to @rohanpaul_ai, publishing a model's weights or code for anyone to download counts as an export under the rule, so even open-source releases need a filing first. DeepSeek and MiniMax registered and then kept open-sourcing models.

## Reactions

Some read the move as a reply to US chip restrictions. @trikcode put it this way: the US told China it can't have its chips, and China is now saying the world won't get its cheap models either. Others worry that Chinese open-source releases will be limited to small-parameter models. @hasherezade passed along that worry, which came from @MaxForAI.

The exemption for published research and open-source code, and DeepSeek's and MiniMax's continued releases after registering, suggest the effect may be narrower than the harshest reactions assume. The final text will show how the thresholds are applied.

## Questions this post answers

### What parameter threshold would make a Chinese AI model subject to export controls

Large language models above 2 trillion parameters, or models ranked in the top 10 on performance or safety benchmarks, are covered under China's proposed export control draft. The draft also covers AI agents, computing clusters, and chip designs at 14nm or below. Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max reportedly fall within the size threshold, though no specific models are named in the draft itself.

_Teams evaluating Chinese open models for production use track policy shifts like this on daily.dev._

### Does China's proposed AI export control apply to open-source models or foreign API access

No, open-source code and published research are exempt from the proposed export controls, and Chinese firms can continue serving overseas users through apps, websites, and APIs. The restriction targets shipping the underlying technology itself, such as model weights or chip designs, rather than foreign customers accessing it as a service.

_Developers weighing self-hosted versus API access to Chinese models follow regulatory distinctions like this on daily.dev._

### When does China's new AI and chip export registration rule take effect

A temporary export registration rule took effect on 16 October, requiring firms to register before exporting listed items, including incomplete deals. Public comments on the broader draft covering 23 AI technologies are open until 15 November, meaning the final scope of controlled models, chips, and AI agents could still change.

_Anyone sourcing AI hardware or models from China watches deadlines like these play out on daily.dev._

## Community discussion

Top comments from developers on daily.dev.

**@patrickwanko** · 0 upvotes

> The question has always been when, and Now might be the answer.

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---

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