China requires prior registration to export 40 AI, biotech and solar technologies

China’s Ministry of Commerce (MOFCOM) and Ministry of Science and Technology published Notice No. 48 on October 16, proposing to add 40 technologies to the Catalogue of Technologies Prohibited or Restricted from Export. There are 23 in artificial intelligence (large models, agents, computing clusters and information processing), 5 in biomedicine (cell and gene therapy, small nucleic acid drugs and pathogenic microorganisms) and 12 in solar (polysilicon, wafer and cell manufacturing).

For solar, the text says the scope also covers the key and core equipment that embodies these technologies. In AI, technologies already in the public domain through open source or academic papers are excluded. In biomedicine, licences that do not transfer ownership will get facilitation such as automatic licensing.

Until the catalogue is formally revised, exporters must register in the MOFCOM system before exporting any listed technology, including deals already started but not completed. Registration covers transfers of intellectual property, licences for use abroad and changes of a technology’s controller to a foreign entity. Comments are accepted from October 16 to November 15.

CSP take: for anyone negotiating with Chinese manufacturers to assemble cells or modules in Brazil or elsewhere, technology and line-equipment transfers now carry a regulatory step in Beijing. Build that risk into timelines and contracts. This reading is ours, not MOFCOM’s.