NoiseOrSignal

If you run a Chinese open-weight model on your own servers outside China, this is about you.

On October 16, China’s commerce and science ministries published Announcement No. 48, a draft revision of the export catalogue that covers 23 AI technology items. Public comment closes November 15. The catalogue is still a draft, but a temporary pre-export registration rule is already live for technology transfers, overseas licensing, and ownership or control changes inside its scope.

MOFCOM’s explanation separates using a model through an API, app, or SaaS from deploying it overseas on your own machines. That separation isn’t a blanket pass for every model or every deal.

My read: for a while, the question was where a model’s chips came from. Now it may also be where the model runs and who controls the technology behind it.

Your pick: treat calling a hosted API and downloading weights for overseas deployment as two different things, and don’t let “open weights” do your compliance thinking for you. If you have a covered deployment or transfer coming up, read the final rules and get proper advice first. November 15 is when comments close; it is not your deadline.

12 months: more model evaluations include deployment and licensing constraints.
24 months: export terms influence more hosting decisions.
36 months: more products keep region-specific model options.

Why I may be wrong: the draft can change, and for most builders cost and capability will keep mattering more than compliance friction.

Do you know, for every model in production, where the weights came from and where they run?