China’s rate of COVID-19 infections has declined significantly and there have been very few domestic infections with most new cases resulting from people flying in to China from overseas.
The government is taking measures to encourage business to assist economic recovery which is making more and more business people consider travel to China in order to take advantage of the opportunities that are likely are to become available. However the rules on movement of people and quarantine remain complicated and it is important that anyone planning a visit to the PRC, prepare carefully.
Preliminary Points to Note
One important point to note is that local rules will apply. Travellers need to consider this when planning through which city to enter China. Also, the fact that there are separate rules applicable to domestic travel within China makes multi-city travel more complicated.
It is important to remember that not all rules are contained in formal notices but very often come in the form of instructions issued by local Neighborhood Councils (being in effect the lowest-level of government). Sometimes, announcements are made through press conferences and distributed through notices sent to individual buildings/building management companies.
Major City Rules
Beijing – Mandatory quarantine applies to all arrivals from overseas regardless of travel history. This means a stay in a government-designated facility (with very limited exemptions such as pregnant woman who may self-quarantine at home) for the full 14 day period. In view of the large number of Chinese citizens returning from overseas all Beijing-bound international flights are being sent to 12 other designated airports in order to avoid crowding in Beijing. After screening formalities, those who meet the quarantine requirements may proceed to Beijing but on the basis that they undergo the required 14 day mandatory quarantine in a government-designated facility (or in the case of very limited exemptions including pregnant women, self-quarantine at home).
Shanghai – Until recently Shanghai based its rules on a list of 24 highly infected countries but as from 26 March, Shanghai has dropped this list completely and required all international travelers (regardless of where they are flying from, with only very limited exceptions) to undergo 14 days quarantine. Self-quarantine was allowed initially but as from 28 March, Shanghai has taken the same approach as Beijing and now requires international travellers to undergo 14 days quarantine in a government-designated facility.
New National Guidance
On 26 March the PRC Ministry of Foreign Affairs issued a Notice temporarily suspending the right of entry to all foreign nationals holdings visas as from midnight on 28 March.
China has also introduced new rules limiting routes, flight frequency and passenger numbers (airlines wishing to fly into China being limited to one flight per week at a maximum of 75% capacity) effective from 29 March.
Transit/domestic travel - The position regarding anyone arriving elsewhere in China before transiting to Beijing is complex.
- Anyone wishing to travel by train or aircraft to Beijing from elsewhere in China within 14 days of entering the country from overseas (if permitted under the policy of the arrival city) must (i) before entering China, provide information regarding his/her health condition and travel plan to his/her residential building management and employer (who would also need to report the travel history to the authorities) and, (ii) upon arrival in Beijing, directly go to the designated gathering site in the train station or airport for transportation to a government-designated facility for quarantine.
- As from 27 March, international travellers who fly in to Shanghai and intend to transit to other provinces and cities (except for Jiangsu Province, Zhejiang Province and Anhui Province) are required to complete 14 days in quarantine at government-designated facilities in Shanghai first.
- Note also that there are rules for arrivals from overseas arrivals and separate rules for arrivals originating within China but outside of Beijing – so, for example, someone arriving in Shanghai and completing 14 days in quarantine in Shanghai would need to serve 14 days self-quarantine upon arrival in Beijing.
No Easy Solutions
In order to illustrate the different rules applicable to various circumstances in which business travellers may find themselves, we set out below three possible examples.
Scenario A: Dirk is regional manager for a United States fast food chain and is based in South Korea. Dirk holds a United States passport. He has been asked by his head office to go to Beijing and Shanghai in order to investigate some of the relaxations in foreign investment rules recently announced by Government.
Dirk is aware that the Government has recently imposed a temporary restriction on foreign nationals entering China and he has therefore dropped his plan, but has instead asked his colleague Alfred, a permanent Hong Kong resident, to travel.
- Anyone arriving in Beijing or Shanghai from overseas will be subject to the 14-day quarantine period at a government-designated facility. This will clearly apply to Alfred.
- If Alfred were to remain in Shanghai and complete his 14-day quarantine period, he could travel on to Beijing but would then also be subject to quarantine rules applicable to domestic travellers – this would require him to undergo self-quarantine in Beijing for a period of 14 days before going onto his meetings.
- Alfred is no longer allowed to travel straight to Beijing following his arrival in Shanghai.
Scenario B: Julia is the largest buyer of ladies’ shoes in Mongolia and plans to fly to Shanghai and Beijing to meet suppliers. She is confused by the regulations and is uncertain about quarantine rules that will apply to her.
- Julia comes from a country that was not on Shanghai’s list of highly infected countries and regions and therefore upon arrival in Shanghai, she would have previously not been subject to any quarantine rules but would have been encouraged to self-quarantine for a period of 14 days.
- However, since she is a foreign national, the recent change in the rules means she is now not permitted to enter China at all.
- Julia must therefore rely on her business associate Anne, who is based in Shanghai. Provided that Anne has a green Sui Shen Ma (i.e. a health code displayed on a mobile telephone), she will be able to visit suppliers in Shanghai. Upon arrival in Beijing Anne must complete 14 days self-quarantine in her hotel.
Scenario C: Doris runs a yoga school based in Beijing and wishes to travel to Shanghai for meetings about possible expansion before returning home. She sometimes visits South Korea and would like to do so before returning to Beijing
- Doris will face no restrictions upon arrival in Shanghai provided that she has no travel history in key countries or areas and has a green Sui Shen Ma and may conduct her meetings as planned.
- If Doris were to travel to South Korea she would face the same issues as Alfred when returning to Beijing.
- If she drops her trip to South Korea, upon returning to Beijing however, she will need to self-quarantine for 14 days at a hotel (or her residence).
Need for Review
The PRC authorities are consistently reacting to changing circumstances in terms of government policy within the PRC, developments overseas and the number of people arriving in the PRC.
The rules described above are likely to change further and it would be advisable for anyone considering coming in to the PRC to check the detailed rules on the day of their travel. Anyone planning to be in the PRC and visit more than one city should take into account the very real risk of the rules changing in respect of travel and quarantine requirements during the course of their visit.