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 deployment 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.
