Chinese model developers can keep selling API and app access abroad, while hosting restricted models locally for overseas clients would come under export management once the catalog is final.
China’s proposed export curbs on artificial intelligence would leave Chinese model developers free to keep selling access to their systems abroad, while pulling some of the ways they build businesses overseas under export management. The Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST) issued the draft on October 16. It would add 40 technologies to the national export-control catalog, 23 of them in AI, with 14 of the 40 to be prohibited and 26 restricted, according to the Ministry of Commerce’s published spokesperson Q&A. Comments are open from October 16 to November 15, Xinhua reported.
The commercial question is how much friction the rules add for companies taking Chinese models to foreign customers. Zhang Yi, founder and chief analyst at consultancy iiMedia, told the South China Morning Post that the measures would bring "short-term adaptation costs" for Chinese companies aiming at international markets. The newspaper, which is owned by Alibaba, framed the trade-off as near-term cost against firmer state control of a strategic sector, and flagged the effect on open-weight models, whose trained parameters are published for anyone to download, as a key uncertainty.
MOFCOM’s own explainer narrows part of that uncertainty. It answers directly whether the various forms of going abroad would count as technology exports, and the answer separates selling a service from moving the technology itself. EastFrontier’s earlier reading of the consultation set out the registration mechanics; the focus here is what the line means for revenue models.
MOFCOM keeps the main overseas sales channels outside the catalog
The Q&A says that when a company uses a restricted large model to offer API calls, app or web interaction, SaaS products or lightweight on-device deployment, the activity falls outside large-model technology export management. The Taipei Times, carrying a Bloomberg report, noted that Moonshot AI’s Kimi K3 and DeepSeek’s latest models compete abroad on price, and that Z.AI sells its products through US cloud providers such as Amazon Web Services.
MOFCOM’s explainer says the vast majority of AI technologies could still be exported freely. The restrictions bite when a restricted model is deployed locally overseas, which MOFCOM places inside export management. A deployment on a company’s own overseas cloud, which the ministry treats as relatively controllable, could qualify for automatic licensing. The Q&A extends similar facilitation to exports tied to open-source AI, Chinese firms’ own overseas computing centers, chip tape-out and manufacturing abroad, joint research using overseas resources, and international standards work.
The thresholds decide which models are restricted in the first place. The draft does not name models, but AP reported that models with 2 trillion or more parameters, or with certain world-leading capabilities, could be restricted, and that Kimi K3 and Alibaba’s Qwen 3.8-Max are among models exceeding that parameter count.
Open-weight releases are the least settled part of the plan
Chinese developers have built international reach partly by publishing model weights, an approach the Bloomberg report described as a way of drawing in developers. MOFCOM proposes that technology which has already entered the public domain through open-source release or academic papers would stay outside export management, a point also reported by the South China Morning Post in its first report on the draft.
That wording covers models already released. The passages of the explainer reviewed for this report do not say whether a developer could publish the weights of a new model above the thresholds without first clearing it as a restricted export. The answer matters for any company whose overseas strategy depends on open releases timed with new model launches, and it is the gap the South China Morning Post flagged.
Deals that change ownership carry a more immediate cost. Under the temporary registration rule, exporters must register covered transfers from the date of the announcement until the revised catalog takes effect, including transfers of ownership, licensing of Chinese technology for overseas use, and changes that put a technology’s owner under foreign control. TechNode Global noted that unfinished transactions are included and that registration does not amount to approval.
Beijing presents the curbs as routine while analysts read a wider contest
MOFCOM says the revision does not target any particular country, region or entity, and that the government supports companies’ lawful cross-border operations and international technology cooperation. Analysts quoted by AP placed it in a broader pattern. Lian Jye Su, chief analyst at Omdia, said it "can be seen as a response to Western countries posting sovereignty requirements on AI," while Gary Ng, senior economist at Natixis, said the world is fragmenting "in access to technologies."
For developers, the near-term costs fall mostly on compliance work, deal timing and decisions about where to host models abroad, since the API and app routes remain open. The longer-term effect depends on how the final catalog treats open releases of models above the thresholds. The version issued after comments close on November 15 will show whether MOFCOM writes an explicit rule for new open-weight launches or leaves the public-domain wording as it stands.