, front page
InitialReach
How we report

SemiconductorsChina technology export catalogueChanged

China moves AI and memory chip design toward export licences and requires registration now, a commerce and science ministry draft shows

China's commerce and science ministries propose adding chip design technology to the technologies that are restricted for export and need a licence: the design of AI processors, of 3D NAND flash and DRAM memory, and the high-speed links that join AI chips in clusters of more than 10,000 accelerators. Until the revised list takes effect, exporting any technology in the draft has to be registered with the commerce ministry first.

The draft, Announcement No. 48 of 2026, was issued on 16 October and covers 40 technologies in AI, biomedicine and solar power. Comments close on 15 November. Registration applies from 16 October, including to exports already under way.

Technology already public through open source or academic papers is left out. For AI technology, the ministries propose automatic licences when it is open-sourced, or exported for Chinese companies' own data centres abroad, for having chips made abroad, for joint research or for work on international standards.

Exporting AI or memory chip design technology from China

Before: Not in the catalogueNow: Register first; licence proposed

What changed

Now Announcement No. 48 of 2026, 16 October 2026

  1. AI processor design

    Before

    Not in the catalogue

    Now

    Proposed as restricted: architecture, own instruction sets, IP cores and software stacks for AI chips meeting any one of six criteria, from 14 nm or finer manufacturing and 2.5D or 3D packaging to “floating-point or integer computing capability”

  2. Memory chip design

    Before

    Not in the catalogue

    Now

    Proposed as restricted: 3D NAND at 8 Gb per mm² or more, at 1.5 Gbps I/O or more, or using bonding; DRAM at 18 nm or finer, with vertical-channel transistors, bonding or multi-layer stacking

  3. AI computing clusters

    Before

    Not in the catalogue

    Now

    Proposed as restricted: chip-to-chip or node-to-node links of 800 GB/s or more, and fault-tolerance, scheduling and mixed-vendor technology for clusters of more than 10,000 accelerators

  4. Before exporting a listed technology

    Before

    No registration

    Now

    Registration on the commerce ministry's platform, from 16 October until the revised catalogue takes effect, also for exports already under way

What stayed the same

  • Chips themselves are outside this draft: it lists technology, and the commerce ministry's spokesperson says products made with the technologies are not covered. For solar, the key equipment is included.

What we don't know yet

  • When the revised catalogue takes effect, and whether the chip items change after the comments.
  • How broadly “floating-point or integer computing capability” will be read. In the draft it is enough on its own to bring an AI processor design into scope.
  • Whether registration can hold up an export. The announcement says what to register, not what happens next.
Check our translation The changed clauses in the original, beside our English

  1. AI processor design (draft)

    具有以下任一特性的人工智能处理芯片设计技术，包括芯片架构、自研指令集、智能计算知识产权核、配套基础软件栈等：（1）需使用14纳米及以下制造工艺；（2）具备浮点或整型运算能力；（3）采用2.5D、3D先进封装集成技术；（4）具备高速互联能力；（5）基于存算一体、类脑计算等非冯·诺依曼架构的新型架构；（6）可应用于自动驾驶、计算机视觉、智慧语音等特定场景。

    AI processing chip design technology with any of the following characteristics, including chip architecture, self-developed instruction sets, intelligent-computing IP cores and supporting basic software stacks: (1) requires a manufacturing process of 14 nm or below; (2) has floating-point or integer computing capability; (3) uses 2.5D or 3D advanced packaging integration; (4) has high-speed interconnect capability; (5) a new non-von Neumann architecture such as compute-in-memory or brain-inspired computing; (6) can be applied to specific scenarios such as autonomous driving, computer vision and smart voice.

  2. Memory chip design (draft)

    （1）具有以下任一特性的3D闪存芯片设计技术：1）存储密度≥8吉比特每平方毫米（Gb/mm2）；2）I/O速率≥1.5吉比特每秒（Gbps）；3）采用键合技术。（2）具有以下任一特性的内存芯片设计技术：1）需使用18纳米及以下内存制造工艺；2）采用垂直沟道晶体管架构；3）采用键合技术；4）进行多层堆叠。

    (1) 3D flash chip design technology with any of: storage density of 8 Gb/mm² or more; I/O rate of 1.5 Gbps or more; bonding technology. (2) DRAM chip design technology with any of: a memory manufacturing process of 18 nm or below; a vertical-channel transistor architecture; bonding technology; multi-layer stacking.

  3. Cluster interconnect (draft)

    用于大规模智能算力集群的片间或节点间高速互连技术，双向带宽≥800吉字节每秒（GB/s）。……注：“大规模智能算力集群”指人工智能加速卡总数超过10,000张的运算主体。

    High-speed chip-to-chip or node-to-node interconnect technology for large-scale intelligent computing clusters, with bidirectional bandwidth of 800 GB/s or more. … Note: a “large-scale intelligent computing cluster” is a computing entity with more than 10,000 AI accelerator cards in total.

  4. Registration (in force)

    自本公告发布之日起，至《中国禁止出口限制出口技术目录》正式修订并实施之日止，技术出口经营者在出口本公告附件所列技术前，应当在商务部业务系统统一平台技术贸易管理信息应用（https://ecomp.mofcom.gov.cn）登记。已经开始但尚未完成的出口，在登记范围内。

    From the date of this announcement until the revised Catalogue of Technologies Prohibited or Restricted from Export takes effect, technology exporters shall register on the technology trade management application of the commerce ministry's unified business platform (https://ecomp.mofcom.gov.cn) before exporting a technology listed in the annex. Exports that have begun but are not finished are covered.

  5. Automatic licences (draft)

    对本类技术开源，以及中国企业在境外自建自营算力中心、赴境外开展芯片流片制造、利用境外资源开展联合研发、参与国际标准制定等情形的技术出口，适用自动许可等便利措施。

    Automatic licensing and other facilitation measures apply to open-sourcing technology of this class, and to technology exports for Chinese companies building and running their own computing centres abroad, carrying out chip tape-out manufacturing abroad, joint research and development using overseas resources, and taking part in setting international standards.

The documents

For people in the field Identifiers, citations and the trade's shorthand, from the documents
Instrument
MOFCOM–MOST Announcement No. 48 of 2026, 16 October, under the Foreign Trade Law and the Regulations on the Administration of Technology Import and Export: draft revision of the Catalogue of Technologies Prohibited or Restricted from Export, with temporary pre-export registration. Comments to MOFCOM's Bureau of Security and Control until 15 November.
Items
Restricted part, AI section of Annex 1: No. 10, 266506X, AI chip design technology (AI processors; 3D flash and DRAM design); No. 11, 266507X, AI computing cluster technology. A large-scale cluster is one with more than 10,000 AI accelerator cards.
Cluster thresholds
Any one of, by technology: interconnect at 800 GB/s bidirectional or more; checkpoint-recovery MTTR of 120 seconds or less, visible training interruption of 30 seconds or less, or GPU compute lost to network faults of 5% or less; linear scaling of 98% or more, topology-aware routing with end-to-end latency of 1 µs or less, or communication hiding of 90% or more; unified scheduling of AI chips from two or more vendors that meets set bandwidth, throughput, cost or availability thresholds.
Registration
On ecomp.mofcom.gov.cn before export, for an assignment of ownership (such as an IP transfer), a licence for use abroad, or a change of owner or actual controller to a foreign entity. The form asks for exporter and recipient, destination, the technology and its use, and the expected value.
Scope of the draft
40 technologies: 23 in AI (large models, agents, computing clusters, information processing), 5 in biomedicine, 12 in solar; 14 proposed as prohibited, 26 as restricted (spokesperson). Public technology (open source, published papers) excluded. For solar, the key and core equipment that carries the technology is included.