Key Takeaways
- • China's MOFCOM and MOST proposed on October 16, 2026 (Announcement No. 48) adding 40 AI, biomedicine and photovoltaic technology control parameters to the Catalogue of Technologies Prohibited or Restricted from Export, with 14 proposed for prohibition and 26 for restriction requiring a license.
- • An interim technology export registration requirement took effect October 16, 2026, covering transfers of technology ownership, licensing of technology in China to foreign entities, and changes in control of such technology, and remains in force until the revised Catalogue takes effect.
- • Three MOFCOM/GAC announcements issued October 19, 2026 (Nos. 49-51) revise dual-use controls on UAVs, tunnel boring machines and dredgers, effective November 18, 2026, while also introducing some easing measures such as per-shipment registration for certain UAVs.
- • Announcement No. 52 formalizes GAC inquiry procedures for undeclared-license dual-use shipments, introducing 15 plus 15 working-day review timelines that replace the previous lack of any deadline under Announcement No. 123 of 2025.
- • Draft civil aviation measures released October 13, 2026 would replace individual licensing with a 60-day single-use export certificate system for certain dual-use aviation items, with comments due November 13, 2026.
Summary
Between October 13 and October 19, 2026, China's Ministry of Commerce (MOFCOM), working with several agencies, released a package of export control measures that broadens the regime across technology, dual-use goods and customs enforcement, according to International Trade Alert. MOFCOM emphasized that the new controls are "precise and limited" and are paired with facilitation measures, though not all facilitation details have been published. The interim technology registration requirement is already in force, while the scope of controlled technologies and of registrable activities remains unsettled.
On October 16, 2026, MOFCOM and the Ministry of Science and Technology issued Announcement No. 48, proposing 40 technology control parameters: 23 in AI, five in biomedicine and 12 in photovoltaics. Fourteen are proposed for prohibition and 26 for restriction, requiring a license. AI controls cover deep-synthesis authenticity verification, AI-driven malicious-code generation, large models trained on "core" or "important" data, high-performance AI agents, certain AI and memory chip design technologies, and interconnect technologies for clusters above 10,000 accelerator cards. Open-source and publicly disseminated technologies are exempt. Biomedicine controls prohibit outbound transfers of ownership of proprietary cell and gene therapy and siRNA platforms and gain-of-function technologies for pathogens, while restricting discovery technologies for new targets. PV controls cover polysilicon, wafer, cell and perovskite technologies, and MOFCOM states that products made with listed technologies are not themselves controlled. Comments on the proposal are due November 15, 2026.
The interim registration requirement, effective October 16, 2026 until the revised Catalogue takes effect, covers transfers of technology ownership abroad, authorization of in-China technology use by foreign entities, and changes in ownership or control of such technology. It also applies to exports begun but not completed as of October 16. Exporters must submit detailed transaction information through MOFCOM's Unified Business Platform and are responsible for self-determining scope. Analysts note that the authorization trigger could capture joint R&D and design-file sharing, leading Chinese counterparties to potentially register in ambiguous cases.
On October 19, 2026, MOFCOM and the General Administration of Customs (GAC) issued Announcements No. 49, 50 and 51, all effective November 18, 2026. For UAVs, the Equipment Development Department of the Central Military Commission joined the issuance. Announcement No. 49 raises the endurance threshold for certain controlled UAVs from one to three hours, which narrows controls for some models, while adding licensing requirements for autopilots, specified engines, components and related software. Announcement No. 50 controls shield and rock tunnel boring machines and certain excavators and shotcrete machines, requiring licenses only for exports to sensitive countries in disputes with China and registration elsewhere. Announcement No. 51 adds license requirements for large dredger slurry pumps, dragheads and cutterheads above size thresholds.
Announcement No. 52, also issued October 19 and effective immediately, replaces GAC Announcement No. 123 of 2025 and formalizes inquiry procedures for shipments declared without a license that may contain controlled items. GAC must complete its review or refer the matter to MOFCOM within 15 working days, and MOFCOM has 15 further working days to decide, with clocks excluding supplementation and testing time and not applying to complex cases. The procedures cover cross-border e-commerce, traveler-carried items and postal shipments, and exporters must now provide invoices, transport documents and a legal basis for treating goods as uncontrolled.
Separately, MOFCOM's October 13, 2026 draft would replace individual licensing for certain civil aviation dual-use items, including fuel controllers, inertial navigation instruments, gyroscopes, altimeters and turbofan engines, with a single-use export certificate valid for 60 days for eligible exporters. Comments are due November 13, 2026. Taken together, the measures tighten controls in sensitive technology sectors while easing several routine dual-use categories for trusted exporters.
On October 16, 2026, MOFCOM and the Ministry of Science and Technology issued Announcement No. 48, proposing 40 technology control parameters: 23 in AI, five in biomedicine and 12 in photovoltaics. Fourteen are proposed for prohibition and 26 for restriction, requiring a license. AI controls cover deep-synthesis authenticity verification, AI-driven malicious-code generation, large models trained on "core" or "important" data, high-performance AI agents, certain AI and memory chip design technologies, and interconnect technologies for clusters above 10,000 accelerator cards. Open-source and publicly disseminated technologies are exempt. Biomedicine controls prohibit outbound transfers of ownership of proprietary cell and gene therapy and siRNA platforms and gain-of-function technologies for pathogens, while restricting discovery technologies for new targets. PV controls cover polysilicon, wafer, cell and perovskite technologies, and MOFCOM states that products made with listed technologies are not themselves controlled. Comments on the proposal are due November 15, 2026.
The interim registration requirement, effective October 16, 2026 until the revised Catalogue takes effect, covers transfers of technology ownership abroad, authorization of in-China technology use by foreign entities, and changes in ownership or control of such technology. It also applies to exports begun but not completed as of October 16. Exporters must submit detailed transaction information through MOFCOM's Unified Business Platform and are responsible for self-determining scope. Analysts note that the authorization trigger could capture joint R&D and design-file sharing, leading Chinese counterparties to potentially register in ambiguous cases.
On October 19, 2026, MOFCOM and the General Administration of Customs (GAC) issued Announcements No. 49, 50 and 51, all effective November 18, 2026. For UAVs, the Equipment Development Department of the Central Military Commission joined the issuance. Announcement No. 49 raises the endurance threshold for certain controlled UAVs from one to three hours, which narrows controls for some models, while adding licensing requirements for autopilots, specified engines, components and related software. Announcement No. 50 controls shield and rock tunnel boring machines and certain excavators and shotcrete machines, requiring licenses only for exports to sensitive countries in disputes with China and registration elsewhere. Announcement No. 51 adds license requirements for large dredger slurry pumps, dragheads and cutterheads above size thresholds.
Announcement No. 52, also issued October 19 and effective immediately, replaces GAC Announcement No. 123 of 2025 and formalizes inquiry procedures for shipments declared without a license that may contain controlled items. GAC must complete its review or refer the matter to MOFCOM within 15 working days, and MOFCOM has 15 further working days to decide, with clocks excluding supplementation and testing time and not applying to complex cases. The procedures cover cross-border e-commerce, traveler-carried items and postal shipments, and exporters must now provide invoices, transport documents and a legal basis for treating goods as uncontrolled.
Separately, MOFCOM's October 13, 2026 draft would replace individual licensing for certain civil aviation dual-use items, including fuel controllers, inertial navigation instruments, gyroscopes, altimeters and turbofan engines, with a single-use export certificate valid for 60 days for eligible exporters. Comments are due November 13, 2026. Taken together, the measures tighten controls in sensitive technology sectors while easing several routine dual-use categories for trusted exporters.
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