China's interim AI export registration covers unfinished transfers
U.S. buyers awaiting AI technology from China should identify the remaining deliverables and obtain the Chinese exporter's classification and relevant registration evidence before the next covered transfer. The interim registration duty already applies while proposed restrictions remain under consultation.
China's October 16 notice put interim registration into effect immediately while opening consultation on proposed export restrictions. The registration duty covers listed technology exports already under way but unfinished.
Chinese technology exporters must register before a covered export. Buyers should ask suppliers to identify the remaining deliverables, map them to the notice's annex and provide relevant registration evidence. Technology already in the public domain through open source or academic publication is excluded. An earlier contract signature alone does not establish that a transfer is complete.
Read the full analysis: China's AI Export Registration Reaches Unfinished Transfers.
Gellert's October 20 complaint includes a separate claim that duties on September additions were collected before Section 338's 30-day waiting period expired. Screen for articles first listed in Proclamations 11064 or 11065, entered for consumption or withdrawn from warehouse for consumption from September 15 through October 7, with Section 338 duties paid. Track those duties separately as a contingent claim that could succeed even if the broader tariff challenge fails. The complaint itself establishes neither class certification nor a refund entitlement, and recovery depends on the court's ruling and the relief granted.