In implementing the overall strategy of “containing the sources of COVID-19 infection and cutting off channels of transmission,” the National Immigration Administration in the People’s Republic of China (“PRC” or “China”) recently called on the public to reduce unnecessary cross-border travel in order to effectively reduce the risk of “contracting the virus when abroad and spreading upon return.” At the same time, to assist individuals who need to leave China for urgent reasons, the Shanghai Exit-Entry Administration Bureau has established a “green channel” during the city lock-down. In addition, the Chinese embassies in the United States, Spain, Poland and other countries have announced relaxed pre-departure inspection requirements for people entering the People’s Republic of China from these countries.1  

WHY THIS MATTERS

Foreign nationals working in the People’s Republic of China and businesses with operations there are affected by the entry and exit procedures and will want to plan accordingly. 

New Policies

The following policies2 have been enacted for the purposes of domestic pandemic prevention and control in recent months:

  • The National Immigration Administration has clarified that it will strictly implement exit-entry policies, restrict non-essential exits by Chinese citizens, and approve the issuance of exit-entry documents.
  • The Shanghai Exit-Entry Administration Bureau has opened a “green channel” for visa applications for those who need to leave China for urgent reasons during the lockdown period.
  • The Chinese embassies in the United States, Spain, Poland and other countries have announced updates to the requirements for pre-departure COVID-19 testing and pre-departure self-health monitoring for people entering China.

Green Channel

On 28 April 2022, the Shanghai Exit-Entry Administration Bureau announced that it will open a green channel for individuals who need to leave China for the following urgent reasons:

  • For school commencement;
  • Visit critically ill relatives;
  • Attend relative’s funeral;
  • Participate in major pandemic prevention and control projects.

Individuals who meet one of the above situations can call the National Immigration Administration’s 12367 hotline. After undergoing a preliminary review and making a reservation, individuals can then go to the in-charge Bureau located at 1500 Minsheng Road, Pudong New District to submit the visa or residence permit application along with the relevant documents (which include the health code, itinerary code and negative certificate from a PCR test performed in the past 24 hours).   

Non-Green Channel Processing Suspended

Since 25 March 2022, the Shanghai Exit-Entry Administration Bureau and its sub-bureaus have suspended service until further notice (excluding the green channel). The in-charge Bureau has not yet confirmed when it will resume work. 

Updates to Entry Requirements

Effective 17 May 2022, the Chinese embassies in the United States, Spain, Poland and other countries adjusted the specific requirements for pre-departure testing for individuals entering China. The updates are summarised below.

Country of departure

Effective date

Updates to pre-departure inspection requirements

United States

20 May

—   The following requirements have been removed:

  • PCR test 7 days before boarding
  • Mandatory requirements for self-health monitoring
  • IgM serum antibody detection test

—   The test within 48 hours before departure has been changed to “two PCR tests" from two different designated test centers within 24 and 48 hours of departure

Spain

19 May

—   The following requirements have been removed:

  • The first PCR test and IgM serum antibody test 7 days before departure
  • X-ray or CT test for recovered patients
  • Requirement to submit a self-health monitoring form and vaccination declaration form to apply for a health code

—   Two PCR tests and an antigen test are required before departure

Ireland

18 May

—   Two PCR tests are required before departure

Denmark

18 May

—   The following requirement has been removed:

  • IgM serum antibody test
  • Two PCR tests are required before departure

UAE

18 May

—   The following requirements have been removed:

  • Test on the 21st or 14th day before departure
  • IgM serum antibody test (excluding those who enter China on Etihad Airways)
  • X-ray or CT test for recovered patients

—   Pre-departure health monitoring has been adjusted to 10 days

Poland

17 May

—   The following requirements have been removed:

  • IgM serum antibody test before departure
  • X-ray or CT test for recovered patients

—   Two PCR tests and an antigen test are required before departure

The Netherlands

17 May

—   The following requirement has been removed:

  • X-ray or CT test for recovered patients

—   Two PCR tests are required before departure

Serbia

17 May

—   The following requirements have been removed:

  • IgM serum antibody test
  • Requirement for health code applications for individuals who have been vaccinated for less than 14 days
  • X-ray or CT test for recovered patients
  • PCR test 7 days before departure

—   The “blue health code” is required

Source: KPMG in the People’s Republic of China

KPMG NOTE

In view of the current situation in Shanghai during the lockdown, we recommend the following:   If an individual needs to leave China for urgent reasons or the individual’s residence permit expires during the lockdown, employers and individuals should familiarise themselves with the application channels (i.e., the green channel) so as to facilitate the residence permit application process. Alternatively, they can engage a professional service provider to assist. 

—   For individuals who urgently need to leave China during the lockdown, the employer should properly plan and arrange the individuals' transportation, departure and return processes before the trip.

—   Try to avoid letting foreign individuals’ work permits or residence permits expire while they are abroad. If the expiry is unavoidable, the individuals should re-apply for an entry visa at a Chinese Embassy abroad in a timely manner and complete the relevant entry processes after obtaining a visa.

—   Given a work permit application cannot be submitted during the lockdown, the individuals should present an extension application and proof-of-lockdown certificate to the Exit-Entry Administration Bureau immediately after the lockdown is lifted.

As the spread of COVID-19 in Shanghai has been largely brought under control, government departments will begin resuming work at an accelerated pace. KPMG will continue to track policy developments involving the national and local immigration authorities, and keep you updated about work resumption arrangements that have been proposed by the relevant government departments. Meanwhile, in the coming months, we anticipate that additional Chinese embassies abroad will update pre-departure testing requirements for individuals entering China to facilitate cross-border travel. Should you have any queries regarding these issues, please contact a member of the KPMG Immigration team.

FOOTNOTES

1  Embassy of the People’s Republic of China in the United States, Notice for China-bound Passengers (Updated May 17, 2022).

2  Please see the link (in Chinese): 从严限制中国公民非必要出境!_媒体_澎湃新闻-The Paper.

RELATED RESOURCE

This article is adapted, with permission, from “China Immigration Policy Updates” in China Tax Alert (Issue 10, May 2022), a publication of the KPMG International member firm in the People’s Republic of China.

* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

 

The information contained in this newsletter was submitted by the KPMG International member firm in the People’s Republic of China.

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