China’s Ministry of Commerce and Ministry of Science and Technology published a draft revision to the catalogue of technologies restricted from export this morning. It proposes adding 40 technologies, 23 of them AI related, covering large models, agents, computing clusters and information processing. Public comment runs to 15 November. The Financial Times has it, so does most of the trade press, and r/LocalLLaMA has been working through it all afternoon.

One part is already live rather than proposed: an interim pre-export registration requirement for the listed technologies, in force from the day of the announcement until the revised catalogue is finalised.

The rest is a draft and has not taken legal effect.

The number

The proposed threshold is models at or above 2 trillion parameters, or models judged to have world leading capability, plus AI agents built for defence or critical infrastructure.

Hold that against what this site actually writes about. We looked up Qwen-Image-2.1 on the day it launched and it is 7.1 billion parameters. The video models we publish with are tens of billions. The largest thing most readers here will ever load is a quantised checkpoint in the tens of gigabytes.

The threshold is around 280 times the size of that image model, and it is the smallest number in the draft.

We have also measured something on the other side of it. In September we checked the open-weight model that a widely quoted capability report was built on, and Kimi K3 came back at 2.78 trillion parameters, which is why we wrote at the time that the comparison was measuring two kinds of datacenter rather than anything on your desk. That model would be above this threshold. It was already a model nobody reading this could run.

So the line, as drafted, lands in the same place the hardware line does. The things it covers are things that live on racks.

What is explicitly outside it

Reporting agrees on several exemptions. Calling a Chinese model through an API, an app or a web interface is outside the scope. Software as a service is outside it. Models already published as open source are outside it.

What is inside, by several accounts, is a vendor installing a restricted model on overseas servers, and the transfer of the technology behind such a model, which can extend to ownership and key staff rather than just files.

Where the reporting does not agree

On the question our readers care most about, whether a new open-weight release above the threshold would need approval before publication, the accounts conflict.

One describes open-weight models as exempt where they were made public and not trained on sensitive data, with the restriction falling on the technology transfer rather than the release. Another describes exporters needing approval to publish weights and source code for systems above 2 trillion parameters or in the global top ten by performance and usage.

Those are different regimes and we cannot resolve which is right from secondary coverage. The ministry’s own notice and its question and answer document are the things to read, and we have not read them. MOFCOM has said publicly that the revision targets no particular country and that most AI technology remains freely exportable.

What would actually matter later

Two trillion is a comfortable number. It is comfortable precisely because it is a number.

The clause to watch is the other test, the one about world leading capability or a global top ten ranking. That has no floor. A 7 billion parameter image model will never approach 2 trillion parameters, and could in principle be the best thing in its category in a given month. Whether that second test is read as applying only at frontier scale, or as a standalone trigger, is the difference between a rule about racks and a rule that can reach a model you have on disk.

Nothing about that is decided today, and the comment period exists for a reason. For now, if you run open models at home, the draft as reported does not touch what you do, and the models already on Hugging Face stay where they are.

We will read the final version when there is one.

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