China has moved to tighten control over strategic technologies by proposing substantial additions to its Catalogue of Technologies Prohibited or Restricted from Export. On 16 October 2026 the Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST) published Announcement [2026] No. 48 and opened the proposal to public comment until 15 November 2026.
What the proposal does
The draft would add 40 technologies across three sectors — artificial intelligence, biopharmaceuticals and solar energy — and change how Beijing treats outbound transfers of know‑how and technical collaboration. The approach moves beyond a simple banned-or‑restricted binary and introduces more granular, risk‑based determinations tied to the nature of the export and its technical parameters.
- Scope: 40 new entries across AI, biopharma and solar energy.
- New mechanisms: sector‑specific carve‑outs and a proposed "automatic licensing" system for certain restricted exports.
- Immediate step: exporters must register temporarily with MOFCOM from 16 October 2026 for any technology listed in the proposal.
Temporary registration and a licensing change
Although the Catalogue remains in draft until the consultation closes and any final text is published, the ministries have already attached practical effect to the proposal. Exports of the newly listed technologies became subject to a temporary registration requirement from 16 October 2026. The filing requirement is intended to give the authorities visibility and an early lever of control while rules are finalised.
The proposal also introduces an "automatic licensing" mechanism for some restricted technologies — a departure from China's current technology export regime. Under the draft, certain transfers of restricted items could proceed essentially upon filing, rather than waiting for an explicit licence decision. The ministries said further rules or guidance would be needed to define how automatic licensing will work in practice.
"automatic licensing"
Why businesses should pay attention
The changes have several immediate implications for companies with research, development or collaborative projects in China. First, the enlarged list broadens the kinds of activity that require attention from compliance teams. Firms that develop, transfer or export software, algorithms, biological agents or solar technologies will need to check whether specific projects fall within the new entries.
Second, the move to risk‑based controls means licensing outcomes may depend on technical parameters and the form of the export — for example, whether a transfer is a cross‑border data exchange, an actual physical shipment, provision of design services or a transfer of biological materials. That complexity will increase the importance of technical assessments before decisions on partnerships or data flows are taken.
Regulatory context and likely consequences
The draft sits within a broader global trend where major economies tighten controls on technologies seen as strategically sensitive. For multinational companies, the draft raises immediate practical questions about export compliance, procurement and contractual terms for collaborative research. It also increases legal and administrative overheads: even where a licence is likely, the temporary registration and the potential for case‑specific licence conditions will mean more paperwork and closer scrutiny by Chinese authorities.
Finally, the introduction of sector‑specific carve‑outs and an automatic licensing route suggests Beijing is trying to balance economic and strategic objectives — enabling some flows while preventing others. How that balance will be struck remains a matter for forthcoming implementing rules, and for businesses the safe course is to assume a heightened regulatory posture until the final Catalogue and accompanying guidance are published.
| Sector | Change |
|---|---|
| Artificial intelligence | New controlled technologies added |
| Biopharmaceuticals | New controlled technologies added |
| Solar energy | New controlled technologies added |
Regulated entities and legal advisers will be watching for the guidance that defines how the automatic licensing and the temporary registration work in practice. Until that guidance appears, companies engaging in relevant R&D or transferring technology from China should review projects against the draft, update compliance checks, and consider notifying or registering with MOFCOM where appropriate.
