The Ministry of Commerce has clarified that the primary criterion for determining whether the overseas export of large-scale AI models and their application products is subject to technology export management is whether they entail the transfer of restricted technologies from China to overseas entities. The scope of AI technologies currently under regulation is precisely defined and limited in nature. Following the implementation of these measures, the vast majority of AI technologies will remain freely exportable.

Specifically, the overseas localization deployment of restricted AI technologies is included within the ambit of technology export management. However, if such deployment occurs in controlled environments, such as overseas self-owned clouds, streamlined procedures like automatic licensing can be facilitated. Furthermore, enterprises leveraging restricted large-scale models to provide API access, APP or web-based interactions, SaaS applications, or lightweight local deployments will not be considered as falling under the purview of large-scale model technology export management.