The regulations apply foremost to closed models. Chinese companies mostly release "open models".
And regarding fines, well the track record for EU fines against any big tech companies, US or China, is abysmal. Even if the companies are fined, the fine goes uncollected or is slashed after the big press release.
I am looking as the DSA here...
Why would they not apply to all models? The models with downloadable weights aren’t “open”. Meaning no one can actually give a summary about their training content and security. Which is what they’re asking US labs.
I actually looked up the text in the AI Act:
"The obligations set out in paragraph 1, points (a) and (b), shall not apply to providers of AI models that are released under a free and open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available. 2This exception shall not apply to general-purpose AI models with systemic risks."
https://ai-act-law.eu/article/53/
The why is under:
https://ai-act-law.eu/recital/102/
So the chinese models aren't exactly open like in the EU wants them to be