As international technological and industrial competition intensifies, China is planning to impose export controls on core photovoltaic technologies. On October 16, the Ministry of Commerce and the Ministry of Science and Technology issued Announcement No. 48 of 2026, seeking public comments on revisions to the Catalogue of Technologies Prohibited or Restricted from Export (hereinafter referred to as the Catalogue), and implementing temporary management measures requiring pre-export registration for related technologies. The Catalogue proposes adding 40 key technologies across three fields: artificial intelligence, biomedicine, and photovoltaics, including 12 photovoltaic technologies covering polysilicon manufacturing, wafer manufacturing, and cell manufacturing, with the scope of control extending to key and core equipment that embodies these technologies. In a press briefing, the Ministry of Commerce stated that in recent years, AI, biomedicine, and photovoltaic-related technologies have been increasingly applied in sensitive areas, and major economies have implemented varying degrees of export controls. China, referencing common international practices, is implementing necessary management in accordance with the law to both prevent risks of technology loss of control and improper proliferation, and safeguard normal international technological exchange and cooperation.
Specifically in the photovoltaic sector, as photovoltaic technology finds expanding applications in sensitive areas such as aerospace, national defense, unmanned equipment, and high-security infrastructure, the national security risks arising from photovoltaic technology exports are steadily rising, making timely and moderate regulation necessary. Calls to protect China's core photovoltaic technology foundation have existed for a long time, and their urgency is growing by the day: in recent years, the photovoltaic supply chain has been mired in supply-demand mismatches, with intensifying price competition. Meanwhile, some overseas countries have erected tariff barriers to block Chinese photovoltaic products while heavily subsidizing local manufacturing. Under such pressure and anxiety, it is not uncommon for domestic enterprises to provide full turnkey solutions including equipment, processes, technical services, and personnel training for overseas production capacity projects. Concerns and doubts about the accelerated outflow of Chinese photovoltaic technology—and even some enterprises "transfusing technology at low prices" for short-term gains—are ubiquitous. Against this backdrop, implementing export controls on core photovoltaic technologies and consolidating generational technological leadership has become urgent.
Drawing precise red lines to lock in the generational technology gap
The Ministry of Commerce stated that it supports green technology sharing, and the scope of technologies listed for control this time is limited—other technologies that do not meet the control thresholds can still be freely exported. The announcement lists a small number of key photovoltaic equipment, targeting only situations where they embody technologies meeting the control thresholds. Other photovoltaic equipment not listed is, in principle, not subject to the requirements of this announcement. It also emphasized that exports of key photovoltaic technologies often occur alongside the export, installation, commissioning, improvement, and upgrading of photovoltaic production lines. Export operators engaging in such activities should apply for technology export licenses as required and use the licenses to process foreign exchange, banking, tax, customs, and other relevant procedures.
Data from the China Photovoltaic Industry Association shows that as of the end of 2025, China's photovoltaic industry has ranked first globally for 15 consecutive years in output across four major production segments (polysilicon, wafers, cells, and modules). In 2025, China's global capacity share in these segments was 95.3%, 96.4%, 90.3%, and 76.2% respectively, occupying an absolutely dominant position. However, it cannot be ignored that the rapid expansion of overseas photovoltaic capacity is intensifying competition. Some countries require foreign-funded factories to share and transfer core processes and prohibit controlling stakes, amplifying the risk of China's core technology leakage. This not only causes profit losses and depreciation of technological assets for domestic photovoltaic enterprises, but also poses a threat to China's energy strategic security and the global leading advantage of its photovoltaic industry.
The prominent feature of this round of photovoltaic technology export controls is that they are targeted, balancing precision and moderation, focusing on advanced technologies and core equipment at the forefront of China's iterative development. Controls do not mean sealing off overseas channels—the Catalogue regulates technology exports and builds a protective moat while leaving room for reasonable international technological cooperation. "The draft for comments draws relatively clear export management boundaries for different tiers of photovoltaic technologies," Tan Youru, a photovoltaic analyst at BloombergNEF, told The Paper. For cutting-edge technologies meeting specific thresholds, the Catalogue proposes placing them in the prohibited export category; some leading high-efficiency photovoltaic technologies and key equipment embodying related technologies are proposed for restricted export management; meanwhile, technologies not meeting control thresholds and other unlisted photovoltaic equipment are, in principle, not bound by this announcement.
This means that "some technologies and equipment that are slightly below China's leading level but still internationally competitive can still be freely exported as long as they do not meet the control thresholds, unaffected by these measures," Tan further analyzed. For Chinese companies going abroad, "the mainstream advanced technologies proposed for restriction still retain a path to legally obtain export approval, and Chinese enterprises can register and apply when expanding overseas." For overseas manufacturers, although some of China's most cutting-edge equipment and technologies are subject to export restrictions, overseas manufacturers can still obtain equipment that meets their localization needs. "Although the technical level of such equipment may not match that of China's leading domestic manufacturers, it can still participate in energy transition and supply chain diversification. This subjects the output of some key manufacturing capabilities to stricter management while maintaining space for Chinese enterprises to participate in overseas manufacturing and supply chain cooperation."
As a transitional measure, the Ministry of Commerce clarified that from the date of the announcement's publication until the official revised Catalogue takes effect, technology export operators must register in the Technology Trade Management Information Application on the Ministry of Commerce's unified business system platform before exporting technologies listed in the announcement. Exports already started but not yet completed fall within the registration scope. For exports of key and core photovoltaic equipment listed within the Catalogue's management scope, registration is required in accordance with regulations.
China's photovoltaic generational advantage is difficult to replicate
Tan Youru emphasized to The Paper that beyond equipment and technology, the know-how accumulated in production lines, the stability and cost of energy supply, and worker proficiency are all key factors in industrial competition. From this perspective, across the entire supply chain from polysilicon to modules, China's photovoltaic manufacturing has clear leading advantages globally, and it is extremely difficult for overseas photovoltaic manufacturing to catch up with China in products and technology. "Even in India and the United States, where module capacity is expanding rapidly, there remain obvious gaps in upstream cell and wafer supporting capabilities. Overseas production lines still have significant gaps with China's leading manufacturers in product efficiency, operating costs, and yield rates," he added.
In the upstream photovoltaic segment, China's polysilicon industry's advantages are reflected in its globally dominant production scale, significant cost advantages, and continuously improving technological level. Regarding advanced technologies and equipment, the Catalogue implements tiered controls on the core preparation processes of the modified Siemens method and the silane fluidized bed method. Lü Jinbiao, a specially appointed new energy expert at the Tiangang Think Tank of Tsinghua Suzhou Environmental Institute, told The Paper that Chinese enterprises introduced trichlorosilane modified Siemens method polysilicon production technology 20 years ago. Through process upgrades and transformations, single-line production capacity has increased from thousand-ton levels to 30,000-ton levels, single reduction furnace capacity has increased from dozens of tons to 800 tons, and equipment localization has been achieved, providing autonomous capability for generational technological upgrading. Currently, of China's 3.5 million tons of high-end capacity, 3 million tons are production lines using this technology platform, while the other 500,000 tons use the silane fluidized bed granular silicon process with single-line capacity of 20,000 tons—a high-quality, low-cost leading technology entirely independently developed by Chinese enterprises.
"Whether it is the trichlorosilane modified Siemens process or the silane fluidized bed process, the supporting cold hydrogenation process for byproduct recycling and reuse was independently developed by Chinese enterprises and has reached a single-unit fluidized bed hydrogenation processing capacity of over 250,000 tons," Lü Jinbiao introduced. Currently, overseas projects using the same technology platform as China's polysilicon only include the 100,000-ton modified Siemens method polysilicon project of United Solar in Oman, which began construction in 2023 and commenced production in February 2026. "Apart from international capital, this project's complete equipment, technical design, engineering services, production operations, and management and technical teams are all outputs from China's polysilicon industry." However, the project has now ceased production due to uncompetitive costs.
Yan Dazhou, Chief Scientist in Advanced Materials at China Minmetals, believes that "controls only target cutting-edge technologies that far exceed international average levels and have significant cost and technical barriers. For conventional, already widespread production processes, an open attitude is maintained. This precision both protects national strategic interests and avoids unnecessary interference with normal industry operations caused by an overly broad scope of control." In his view, implementing export controls on core technologies is precisely about adding a "safety lock" to China's energy strategic security. It clearly draws a "red line" for technology outflow, ensuring that core processes representing national competitiveness (such as key technologies, equipment, drawings, algorithms, and process packages) are not lost through disorderly competition or abnormal commercial behavior—a strategic move to safeguard national economic security and the global industrial competitive landscape.
An industry observer told The Paper that with the Catalogue revision, the previous model of some enterprises directly exporting process packages and whole-plant technology authorizations will be constrained, effectively preventing the disorderly outflow of generational leading technologies accumulated over long periods in China and hedging against the dilution of China's industrial chain foundation by overseas local capacity building. In the medium to long term, this will force a shift in industry competition logic—from simply monetizing equipment and process exports to focusing on product exports, compliant equipment trade, and intellectual property licensing. Multiple industry insiders told The Paper that for equipment enterprises, exports of advanced equipment will face short-term adjustments and pain. For integrated leading enterprises, this move can reduce involution caused by low-price technology spillover. After key process and equipment exports are restricted, overseas production lines will face extended equipment procurement, process commissioning, and yield ramp-up cycles, slowing the pace of incremental global effective supply. At the same time, the controls feature a dynamic public comment mechanism, and normal international economic and trade cooperation can still continue under compliance, pushing the global photovoltaic industry from simple capacity transfer toward tiered technological innovation competition, consolidating China's long-term first-mover advantage in photovoltaic manufacturing through dynamic adjustments.
The hidden thread of space competition
Regarding export controls in forward-looking technology fields such as space photovoltaics, the Catalogue does not directly name them, but the direction is very clear. According to the Catalogue, multiple perovskite and tandem cell module production technologies and their equipment manufacturing technologies are included in the prohibited export category. For heterojunction (HJT) crystalline silicon cell preparation technology and its equipment manufacturing technology, "for P-type heterojunction cells, under AM1.5 test conditions, maximum conversion efficiency ≥23%, or under AM0 test conditions, maximum conversion efficiency ≥20.5%" is included in the restricted export category. These provisions point directly at space photovoltaics: P-type heterojunction and perovskite tandem are regarded as mainstream technology routes for short-to-medium-term space photovoltaics, and the AM0 standard is fundamental to space photovoltaic technology development, representing the solar spectrum outside Earth's atmosphere at one astronomical unit from the sun, different from the AM1.5 standard commonly used on Earth's surface.
Space photovoltaics possesses dual attributes of civilian and national defense energy, bearing on national energy security and space strategy. Leveraging decades of deep accumulation in ground-based photovoltaic industrialization, China has first-mover advantages in engineering verification and iteration of space photovoltaics. From late last year to the first half of this year, the "space photovoltaic" concept gained popularity, greatly boosting the long-depressed photovoltaic sector in the secondary market, and discussions around equipment export restrictions subsequently heated up. Musk's Tesla and SpaceX are advancing their respective 100GW self-built photovoltaic capacity targets on dual tracks, with corresponding supply chains known in the industry as the T-chain (ground scenarios) and S-chain (space scenarios). To this end, Musk's team visited multiple Chinese photovoltaic enterprises. The resulting order expectations revived confidence among Chinese equipment manufacturers beleaguered by overcapacity and weak short-term demand. However, many also hold the view that the core technologies embodied in photovoltaic equipment are key to China's global photovoltaic competitiveness, and an export principle based on "technological generational gap" must be established. Cutting-edge equipment often embodies complex underlying processes, and promoting the legalization and standardization of technology and equipment exports while ensuring national security is imperative.
Earlier this year, sources told The Paper that industry regulators were considering issuing classified guidance documents on exports of advanced photovoltaic core equipment. Another industry media report indicated that in early April, development and reform commissions in some provinces and cities urgently summoned local photovoltaic equipment enterprises to survey the situation regarding photovoltaic equipment exports and provide policy guidance. Subsequently, the Ministry of Commerce summoned some photovoltaic material and equipment enterprises to solicit opinions and suggestions on including photovoltaic equipment in controls. "The core technologies of many photovoltaic segments are embedded in the equipment," an industry research analyst told The Paper at the time. "There are no explicit restrictions yet, but there are rumors that equipment imported by India is actually ultimately American, so the risk of technology leakage must be prevented."
"As international competition intensifies, advanced technologies, key equipment, and manufacturing capabilities have become important strategic resources affecting national industrial security. Some countries, on one hand, restrict China's photovoltaic module exports through measures such as raising tariffs, setting trade barriers, and conducting anti-dumping and countervailing investigations; on the other hand, these countries actively attract Chinese enterprises and talent to invest and build factories overseas, attempting to capture China's mature manufacturing capabilities and advanced production technologies," wrote Jia Rui, a researcher at the Institute of Microelectronics of the Chinese Academy of Sciences. In recent years, India launched a production-linked incentive scheme and is actively building a complete photovoltaic manufacturing supply chain; the United States, through the Inflation Reduction Act and other policies, is vigorously promoting the reshoring of local photovoltaic manufacturing; Europe has successively introduced the Net-Zero Industry Act and other policies to accelerate the establishment of local new energy manufacturing capacity; and multiple Southeast Asian countries have introduced policy incentives and industrial transfer measures to attract domestic manufacturers to establish photovoltaic manufacturing bases in those countries.
"However, some enterprises lack overall awareness, vigilance, and national security consciousness, and have transferred core production processes, complete sets of key equipment, manufacturing experience, and process parameters abroad in pursuit of short-term gains," Jia Rui argued. For mature technologies that are already widely applied and commonly mastered in international markets, cooperation can continue to be open, supporting enterprises in conducting international trade in accordance with the law to enhance their international market competitiveness. For advanced photovoltaic technologies, high-end photovoltaic equipment, key process software, and core process databases that have internationally leading advantages and bear on future industrial competitive high grounds, classified management should be implemented based on technological advancement, strategic value, and industrial sensitivity, improving export review, technology assessment, intellectual property protection, and risk management mechanisms.
"China has not set barriers for mature manufacturing technologies and equipment, and still provides cost-effective products to the world, greatly lowering the threshold for global green transition," a senior executive of a domestic photovoltaic enterprise told The Paper. The Catalogue fully embodies the strategy of "comprehensive openness for mature technologies, precise protection for advanced technologies." For example, global photovoltaic competition has extended to space. "Including advanced technologies and core equipment in controls on this new track of great power competition helps build a solid line of defense for national strategic security and prevents China's hard-earned technological generational gap from being disorderly 'equalized.'"
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