China Starts Interim Registration For Proposed Technology Export Controls

Registration Applies During The Catalogue Consultation

China's Ministry of Commerce and Ministry of Science and Technology have opened consultation on additions to the country's prohibited and restricted technology-export catalogue. Announcement 2026 No. 48, published on 16 October, invites comments until 15 November 2026.

A separate interim registration requirement applies from publication until the revised catalogue is implemented. It covers exports of technologies listed in the announcement, including transfers already started but not completed.

Proposal Covers Three Technology Groups

The proposed additions comprise 23 artificial-intelligence technologies, five biomedical technologies and 12 photovoltaic technologies. MOFCOM's official explanation identifies 14 proposed prohibited technologies and 26 proposed restricted technologies. Those catalogue changes remain under consultation.

The photovoltaic scope includes polysilicon, wafer and cell manufacturing. MOFCOM says the listed key equipment is covered where it carries technology meeting the control criteria; other unlisted photovoltaic equipment is generally outside the announcement's requirements.

Covered Transfers Require Pre-Export Information

Registration covers overseas transfers of technology ownership, licensing domestic technology for overseas use, and changes placing domestic technology ownership or actual control with an overseas entity. The announcement also allows other cases expressly specified by MOFCOM.

The required information includes the exporter and recipient, destination, technology and intended use, and expected export value. Exporters must register through MOFCOM's technology-trade information system before the covered export.

MOFCOM distinguishes the technology controls from products manufactured using the technologies. Its explanation nevertheless expressly includes registration for photovoltaic key and core equipment within the catalogue's stated scope.

Current Registration And Proposed Controls Need Separate Tracking

Foresight analysis. An open consultation does not remove the interim registration requirement. Businesses planning covered technology transfers should track that current requirement separately from the proposed future category, and assess photovoltaic equipment against the stated technical scope rather than treating all equipment alike.