China Technology Transfer Control Act of 2025

Regulates the export of technology related to AI and other fields to China by requiring the President to control such exports for national security. Requires the U.S. Trade Representative to annually list AI-related products supported by the Chinese government.

  • Authority: United States Congress
  • Parent authority: Federal government
  • Jurisdiction: United States
  • Collections: U.S. federal laws
  • Most recent activity: Proposed
  • Most recent activity date: 2025-02-07

Risk subdomain coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the risk subdomain are explicitly described.

  • Competitive dynamics

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

  • Disinformation, surveillance, and influence at scale
  • Cyberattacks, weapon development or use

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

The document primarily addresses competitive dynamics (6.4) through export controls aimed at preventing technology transfer that could enhance China's military and economic capabilities. It also addresses malicious actors risks (4.1, 4.2) by restricting technology that could be used for weapons development or human rights violations. Coverage is concentrated in geopolitical competition and national security domains, with minimal direct coverage of AI-specific safety or technical risks.

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

  • Agriculture, Mining, Construction & Manufacturing
  • Information
  • Scientific Research & Development Services
  • National Security

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

  • Trade, Transportation & Utilities
  • Health Care & Social Assistance

All other sectors had no coverage in this document.

Sectors Summary

This is an external regulation that governs technology exports across multiple sectors. The document explicitly lists 16 industries subject to Chinese government support tracking, including AI, semiconductors, biotechnology, robotics, and various manufacturing sectors. The regulation applies broadly to any U.S. person or entity exporting covered technologies to China.

Legislative Status

Hard Law

Legislative Status Summary

This is a binding legislative act from the United States Congress with mandatory export controls, sanctions provisions, and enforcement mechanisms including penalties under the International Emergency Economic Powers Act.

Actors

Proposer

  • Entity Types: AI_Governance_Actor
  • Summary: This is an Act of Congress, as indicated by the title 'China Technology Transfer Control Act of 2025' and the legislative structure with sections and amendments to existing U.S. Code.

Target

  • Entity Types: AI_Developer, AI_Infrastructure_Provider, AI_Deployer
  • Summary: The Act targets any United States person or foreign person that exports, sells, or provides covered national interest technology (including AI) to China, as well as Chinese persons who use such technology in violation of export controls.

Enforcer

  • Entity Types: AI_Governance_Actor
  • Summary: The President is granted authority to control exports, impose sanctions, and prescribe regulations. The Secretaries of State and Commerce must assess implementation mechanisms, and the USTR must maintain lists of covered products.

Monitor

  • Entity Types: AI_Governance_Actor
  • Summary: The USTR is required to annually list products receiving Chinese government support. Congress receives reports and the Secretary of State identifies products used for human rights violations.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

  • Build and Use Model
  • Deploy
  • Operate and Monitor

AI Lifecycle Summary

The document does not focus on specific AI lifecycle stages but rather on controlling the export and transfer of AI technology broadly. It addresses AI as a category of technology subject to export controls without distinguishing between development, deployment, or operational phases.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

No technical scope terms identified.

Technical Scope Summary

The document explicitly mentions artificial intelligence as a category of technology subject to export controls. It does not define AI models, AI systems, or distinguish between different types of AI (frontier, general purpose, task-specific, etc.). There is no mention of compute thresholds, foundation models, generative AI, predictive AI, or open-weight models.

https://www.congress.gov/bill/119th-congress/house-bill/1122
https://agora.eto.tech/instrument/2320
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Document data from AGORA, CSET Emerging Technology Observatory.