Will TikTok’s Core Algorithm Face Export Bans? China’s New Tech Export Controls Explained

On August 28, the Ministry of Commerce together with the Ministry of Science and Technology released an updated “Catalogue of Technologies Prohibited from Export or Subject to Export Restrictions,” explicitly listing “personalized push technology based on data analysis.” The core algorithm of TikTok is considered to fall under this category and may therefore be prohibited from export.

This is not the first revision; the previous catalogue was issued in 2008. According to Professor Cui Fan of the University of International Business and Economics, the current update modifies 53 technology items: 9 prohibited or restricted items are removed, 23 new restricted items are added, and the control points and technical parameters of 21 items are revised.

Professor Cui advises exporters who have not yet completed transactions involving the newly restricted technologies to pause negotiations and trade procedures, and to fulfill the required application and licensing steps.

Using ByteDance as a recent example, the new catalogue’s Item 21 – “personalized information push service technology based on data analysis” – and Item 18 – “artificial‑intelligence interaction interface technology” – could encompass technologies used by TikTok’s algorithm. ByteDance is already under pressure from the U.S. government to divest TikTok, and any export of related technology would now require formal permission.

ByteDance’s rapid international expansion relies on strong domestic technical support, continuously providing core algorithm services to overseas companies. If its international operations continue, the company may need to transfer software code or usage rights abroad, which would be classified as a typical technology service export.

Consequently, experts recommend that ByteDance carefully study the revised catalogue, seriously consider pausing substantive trade negotiations, and complete all statutory filing procedures before taking further action. ByteDance has responded that it will strictly comply with relevant national laws.