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China's AI export plan leaves most SME tools untouched

In brief

On 16 October, China's Ministry of Commerce proposed adding 23 AI-related technologies to its export-control list, including large language models, AI agents and certain compute clusters. According to the ministry, APIs, websites, applications and SaaS platforms would be excluded, as would open models already available. Future very large models above size thresholds could face restrictions.

Source : LeMagIT - « Contrôle à l’export : la Chine laisse planer le doute sur le sort des modèles frontières ouverts »

What it changes for an SME

For an SME with 10 to 250 people, the cost and timing of day-to-day API or SaaS use should not change, according to China's Ministry of Commerce. The main risk is future access to very large Chinese models run on your own servers: licences or registration could apply and lengthen a project. This is not an EU compliance duty; it is a Chinese export-control proposal, not yet adopted. If you do not run Chinese models on premises, nothing requires urgent action.

What you can do

  • List the Chinese AI services and models you use, and separate APIs and SaaS from on-premises installs.
  • Check whether any planned project depends on a future very large Chinese model that may need registration or a licence.
  • Wait for the outcome of this proposal before locking in on-premises hosting of a Chinese model.
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