China Healthcare: New export rules restrict ownership transfer of CGT/siRNA platforms; out-licensing and CRO/CDMO remain supported

On October 16, 2026, China's MOFCOM and Ministry of Science and Technology issued Announcement No. 48 of 2026, soliciting public comments on proposed revisions to the "Catalog of Technologies Prohibited or Restricted from Export." Before the revised catalog formally takes effect, technologies in the consultation draft are subject to temporary pre-export registration. The draft proposes new export regulation on biotechnology, highlighted by cell and gene therapy (CGT), siRNA and pathogenic-microorganism technologies. Goldman Sachs views the proposed policy as narrowly defined, with a tiered framework focused on transfers of foundational platform ownership and selected target-discovery technologies;