CONSULTATION RUNS TO NOV 15 — BUT PRE-EXPORT REGISTRATION IS ALREADY IN FORCE

Public consultation on China's proposed Announcement No. 48 export controls runs until November 15, 2026, but an interim pre-export registration requirement for the affected technologies is already in force. The proposal would add 40 technologies to the control list, 23 of them in AI, covering large language models, agents, chip designs and computing clusters, with model weights and source code in scope for the first time above certain performance thresholds.

The commerce ministry has been consulting domestic firms including Alibaba, ByteDance and Zhipu on the shape of the controls since the summer. API and SaaS access is exempted, and technology already published through open-source releases or academic papers is left alone, so the registration and eventual licensing burden falls on direct transfers of the controlled technology itself.