The new measures unify the testing requirements for China-bound travellers from the same departure location, regardless of their vaccination status, i.e. whether the person is vaccinated, partially vaccinated or not vaccinated, and regardless of the type of vaccine. Below we summarize the basic testing requirements for HDC-Code applications and list the main changes to previous measures.

Basic New Testing Requirements

• First nucleic acid test within 48 hours before boarding 
• Second nucleic acid test within 24 hours before boarding 
• Antigen test within 12 hours before boarding (applicable in certain locations only)

Main Changes

• The requirement of a nucleic acid test seven days before boarding is cancelled. 
• The requirement of an IgM antibody test for unvaccinated or partially vaccinated persons is cancelled.
• Mandatory self-health monitoring requirements are either cancelled or the length of the self-health monitoring period is shortened (depending on location).
• Imaging diagnosis of lung CT or X-ray is no longer required for those who have infection history (applicable in certain locations only).

In comparison with travel policies for inbound travellers to China over the last two years, the latest changes may facilitate inbound travel to Mainland China. Nevertheless, travellers who have an infection history, are close contacts of a person with COVID-19, and travellers with symptoms of COVID-19 will  have to go through additional hurdles.

In terms of epidemic prevention, unnecessary cross-border travel is still discouraged. To effectively manage the risk of epidemic infection at exit and entry, visa applications for inbound travelling foreign nationals and the issuance of passports and endorsement for outbound travelling PRC nationals are still restricted. Additionally, the post-arrival quarantine measures are still strictly implemented without exemptions.

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Zora Mao is an associate of FenXun Partners who is a premier Chinese law firm. FenXun established a Joint Operation Office with Baker McKenzie in China as Baker McKenzie FenXun which was approved by the Shanghai Justice Bureau in 2015.

Baker & McKenzie FenXun (FTZ) Joint Operation Office is a joint operation between Baker & McKenzie LLP, an Illinois limited liability partnership, and FenXun Partners, a Chinese law firm. The Joint Operation has been approved by the Shanghai Justice Bureau. In accordance with the common terminology used in professional service organisations, reference to a "partner" means a person who is a partner, or equivalent, in such a law firm. This may qualify as “Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.

This client alert has been prepared for clients and professional associates of Baker & McKenzie FenXun (FTZ) Joint Operation Office. Whilst every effort has been made to ensure accuracy, this client alert is not an exhaustive treatment of the area of law discussed and no responsibility for any loss occasioned to any person acting or refraining from action as a result of material in this presentation is accepted by Baker & McKenzie FenXun (FTZ) Joint Operation Office.