China's First Frontier AI Export Controls: Mofcom Announcement No. 48

China's Ministry of Commerce and Ministry of Science and Technology have issued a new announcement that adds 40 technologies to the Catalogue of Technologies Prohibited or Restricted from Export, including 23 in artificial intelligence. The announcement proposes restrictions on frontier model weights, agent architectures, and AI-enabled offensive cyber capabilities, and imposes an interim pre-export registration requirement. The catalogue additions are a draft open for comment until November 15, 2026, while the registration requirement applies now, including to exports that have started but are not yet complete. The restrictions are intended to control the export of advanced AI technologies, particularly those that can be used for military or critical infrastructure applications. Enterprise exposure is determined by the line between service access and custody, with API, app, web, SaaS, and lightweight on-device use not counting as exporting a large model. However, deploying a restricted model locally outside China does count, and automatic licensing may apply in certain cases.