China’s First Frontier AI Export Controls: MOFCOM Announcement No. 48
Summary
China's MOFCOM and MOST issued Announcement No. 48 proposing 40 technologies to China's export-restricted catalogue, with 23 AI items and an interim pre-export registration in force now. The draft introduces strict thresholds for frontier models (weights, parameters, and performance benchmarks) and differentiates between API/SaaS access and local deployments, creating cross-border and intra-group licensing considerations. The article outlines practical actions for enterprises—inventory of Chinese-origin AI assets, governance reviews, and vendor/licensing planning—and discusses broader strategic implications in relation to U.S. and Chinese controls.