China: Travel restrictions and Abolition of a "PU-Letter"

The former have dominated the headlines recently due to their global impact, while the latter have received rather little attention. Therefore, we would like to briefly outline here what has happened in recent weeks with regard to a possible opening of China during the pandemic.

Effective 28 March 2022, the People's Republic had already introduced some important changes regarding recognised vaccines for SARS-CoV-2 and required testing procedures for entry. The following vaccines are now recognised:

There must be at least 14 days between the day of receiving the second dose and the date of travel. In the case of booster vaccination, no time interval regulations apply. Also with effect from 28 March 2022, two negative PCR test results (instead of previously one negative PCR and IgM test each) and one negative antigen test result must be submitted for travel from Germany to China. Only PCR test results issued by two different test centres within 48 hours before the scheduled departure time will be accepted. The second PCR test may not be more than 24 hours and the antigen test not more than 12 hours before the scheduled departure time. 

Persons without the required vaccinations must still show negative test reports of an IgM test (48 hours), PCR test (24 hours) as well as antigen test (12 hours).

For some other countries, such as the USA, the UK, Spain, Italy, France, Poland, Ireland, Denmark, Brazil, similar relaxations have been announced by their foreign missions.

Probably the most significant change is the seemingly introduced abolition of the requirement of the so-called "PU letter" for applying for a residence permit. From various sources as well as our own experience in current mandates, we can say with some probability that this previously required official letter of invitation will be abolished in the future for visa categories Z (work visa), Q (visa for foreign family members of Chinese nationals or foreigners with permanent residence permits) and S (visa for family members of foreigners working in China). While there has not yet been a nationwide announcement from the national immigration authority, we have received confirmation of this important change after inquiring with various local authorities. Other visa categories (such as business or tourist visas) are reportedly not (yet) covered by this new regulation.

At the end of May this year, as part of a comprehensive package of economic support measures, the Shanghai government had announced, among other things, that it would make it easier for foreign workers of foreign-invested companies and their family members to apply for PU letters as well as entry procedures. It can be surmised that this is somewhat related to the new entry regulations. This will remove one of the major obstacles that have made it much more difficult for foreign-invested companies to send skilled workers to the People's Republic since the outbreak of the corona pandemic. The procedure for issuing a PU letter took several months and was handled very differently locally. In many cases, the chances of family members being covered by a foreign worker's PU letter were rather slim.

Finally, we can also see some positive developments in domestic travel. For example, in a press conference on 5 June 2022, China's State Council called on all provinces, cities and municipalities in clear terms not to impose any additional hurdles on domestic passenger travel other than those required by law at the central government level. This concerns in particular often observed measures such as

This is a clear signal to put a stop to excessive interpretations of national regulations. However, it remains questionable how these requirements are to be implemented in practice. At the moment it is not apparent that there will be a harmonisation of prevention and control measures throughout the country in the short term. We will continue to monitor developments closely and inform you of any changes in good time.