MOFCOM said whether an AI ‘‘go-global’’ scenario falls within tech export
controls depends on whether restricted-category technology is transferred from
China to overseas. The AI technologies newly placed under regulation are
precisely defined and limited; after implementation, the vast majority of AI
technologies can still be exported freely. For technologies designated as
restricted, localized deployment overseas constitutes a technology export
subject to controls, though deployed on overseas self-owned cloud or similarly
lower‑risk environments may qualify for automatic licensing and other
facilitative measures. By contrast, using restricted large models to provide API
calls, app/web interaction, SaaS, or lightweight local edge deployments does not
fall under large‑model technology export controls.
