LawFlash
June 10, 2022As the COVID-19 landscape continues to evolve, multinational employers face many questions, challenges, and opportunities when considering how to resume global business travel. To help interested parties plan for Asia-Pacific travel, we’ve outlined current entry bans and vaccination and quarantine requirements in China, Hong Kong, Japan, and Singapore. This guidance is subject to rapid change based on the global and local pandemic situation.
CHINA
China’s borders are currently closed, and entry remains strictly controlled. Only the following categories of travelers may enter the country:
- Chinese nationals: People’s Republic of China (PRC) nationals and Hong Kong / Macao / Taiwan residents with valid travel documents to enter China (i.e., Homeland Return Permit or Tai Bao Zheng), but advance permission is required from some locations and recommended for all
- Non-Chinese nationals with long-term entry approval: Chinese Green Card holders and valid residence permit holders under the categories of work, personal matters, and reunion, as long as the purpose for entry is the same as that for the residence permit
- Non-Chinese nationals with short-term entry approval: Holders of valid entry visas issued after the travel ban under the PU/TE invitation letter route or Visa Facilitation Policy route
Applications for entry visas remain closely scrutinized against the COVID-19-related conditions within the PRC and where the applicant is located, but the PU/TE invitation letter requirement has been lifted for Z (work), S (family reunion), and Q (relatives of Chinese nationals or those who have permanent residency in China) visa applicants.
Boarding Requirements
There are testing requirements for entry starting seven days prior to departure. Travelers are generally required to report travel details to the Chinese embassy or consulate at their departure city to obtain a ”green” health code prior to boarding.
The Chinese government has relaxed restrictions for travelers from selected locations by removing the seven-day pre-departure quarantine requirement and the S or N protein IgM antibody test for passengers vaccinated with non-inactivated vaccines and unvaccinated passengers. The testing requirements are replaced by a combination of PCR and antigen tests conducted at specific intervals.
For the above-listed categories of travelers, they must obtain a “blue” health code from the local Chinese embassy or consulate.
It is worth noting that for those who have a COVID-19 infection history, it can be challenging to obtain the “green” health code, and it will generally not be issued if the travel is not considered to be necessary or urgent.
Quarantine Requirements and Pilot Program
The general mandatory quarantine period is 14–21 days, and many cities have their own specific quarantine requirements.
There is currently a pilot program in place to reduce the quarantine period from 14 days to 10 days for incoming travelers and close contacts of COVID-19 cases. This pilot program is limited to a handful of cities including Shanghai, Ningbo, Suzhou, Guangzhou, Xiamen, Chengdu, Dalian, and Qingdao.
Some locations, such as Beijing, are more restrictive and have additional requirements. Currently, international travelers wishing to visit Beijing must generally quarantine for 21 days and produce a negative COVID-19 test within 48 hours of arriving in Beijing. Once in Beijing, they must present another negative COVID-19 test within 24–48 hours, depending on the local neighborhood committee requirements, and may not visit public places, including office buildings, for an additional seven days thereafter.
PRC Nationals Exiting China
While there is no formal restriction for PRC nationals exiting China, passport and exit endorsement applications are currently suspended or significantly prolonged. If there are heavy restrictions from the traveler’s departure city, it may be possible to utilize a third location as an interim stop prior to entering China. We provide two examples below:
- Hong Kong to China: Pre-departure PCR test within 48 hours of departure
- Singapore to China: Seven-day pre-departure self-isolation, two PCR tests in different designated test institutions (one on the second day and one within 24 hours before departure), “blue” health code, and one antigen test within six hours before boarding.
When utilizing a third location for entry to China, travelers must first adhere to the boarding and quarantine requirements of this city prior to onward travel into China.
HONG KONG
In Hong Kong, there has been a gradual decrease in social distancing measures. Currently, all fully vaccinated travelers may enter Hong Kong, regardless of whether they are Hong Kong residents. Those travelers who are not vaccinated can enter Hong Kong only if they are arriving from Mainland China, Macao, or Taiwan.
- Entry from Mainland China, Macao, and Taiwan: Travelers must follow a 14-day quarantine requirement at personal accommodations or observe a combination of quarantine and self-health monitoring depending on vaccination status.
- Outside those jurisdictions: Vaccinated travelers must observe a 14-day quarantine at a designated quarantine hotel, with the possible option to split this as seven days at the hotel and seven days’ self-health monitoring.
In addition, the Hong Kong Immigration Department recently relaxed its visa extension policy whereby visa extensions can be conducted overseas, if the relevant requirements are satisfied. There is also a new vaccination mandate from June 2022; to be considered fully vaccinated, one must have had three doses of vaccine, as opposed to two.
Country risk categorization is subject to rapid change based on the local pandemic situation. The most up-to-date country list and quarantine requirements are published on the Hong Kong government’s dedicated website.
JAPAN
Currently all travelers, including Japanese nationals, entering Japan are in principle required to obtain a suitable (negative) certificate of testing for COVID-19 within 72 hours prior to departing for Japan and must take a COVID-19 test at the airport.
From June 1, 2022, the Japanese government will classify countries or areas in three categories (“Red,” “Yellow,” and “Blue”), and the following quarantine requirements will apply to travelers, depending on a traveler’s vaccination status and the countries or areas where the traveler is coming from.
|
Category |
Does Traveler Have Valid Certificate of Vaccination? |
Test at Immigration |
Quarantine Period |
|
Red (4) |
No |
Implement |
3-day stay in quarantine accommodation (and test result is negative at accommodation) |
|
Yes |
3-day stay at home and voluntary test result is negative (7-day stay at home if not taking a test) |
||
|
Yellow (99) |
No |
||
|
Yes |
– |
No quarantine |
|
|
Blue (98) |
No |
||
|
Yes |
There are 98 countries and areas classified as Blue, including Australia, Austria, Belgium, Brazil, Canada, China, France, Germany, Hong Kong, Indonesia, Italy, Malaysia, Mexico, Netherlands, New Zealand, Philippines, Republic of Korea, Russia, Singapore, South Africa, Spain, Sweden, Switzerland, Thailand, Taiwan, United Kingdom, and United States.
In addition, the upper limit of entrants will be raised from 10,000 people to 20,000 people.
From June 10, 2022, foreign nationals who (a) newly come to Japan for a short-term stay (not more than three months) for business or work purposes, (b) newly come to Japan for tourism purposes (limited to package tours with tour conductors where a travel agent acts as a sponsor company in Japan and foreign nationals come from countries or areas in the Blue category), or (c) newly come to Japan for a long-term stay will, in principle, be permitted entry to Japan if a sponsor company in Japan has completed the Entrants, Returnees Follow-up System (ERFS) registration, and a Japanese visa is issued for such foreign nationals through a Japanese consulate. For a long-term stay, foreign nationals must also obtain a certificate of eligibility for their visa applications at a regional immigration bureau. It has been approximately two years since the last time tourists were permitted to enter Japan.
SINGAPORE
Singapore is in the process of lifting most of its restrictions surrounding social distancing and travel. While individuals are still required to wear masks indoors, there is no requirement for the same while outdoors, and the requirements for mandatory contact tracing have been relaxed.
On the immigration and travel front, currently there are no countries in the “Restricted Category” list for travel. However, various pre-departure and post-arrival testing and quarantine requirements will remain in place for nonvaccinated travelers.
Generally, travelers who are fully vaccinated are able to enter Singapore without pre-departure testing and without any quarantine requirements on arrival. Travelers are deemed to be fully vaccinated if they have either (a) received the full regimen of WHO Emergency Use Listing Procedure (EUL) vaccines and met the minimum dose interval period; or (b) contracted COVID-19 before being vaccinated and received at least one dose of any WHO EUL vaccine at least 28 days from their first diagnosis of a COVID-19 infection. In the latter case, travelers must produce acceptable proof of their first positive COVID-19 diagnosis. Travelers who are not fully vaccinated should test within two days of departing for Singapore and quarantine for seven days on arrival, with a negative test at the end of the seven days.
In addition, all travelers who have a history of travel to countries/regions of Africa and Latin America with yellow fever risk are also required to obtain a yellow fever vaccination certificate. If this is not obtained, they may be turned away from Singapore or be subject to up to six days’ quarantine on arrival.
While Singapore has generally opened up to international travelers, the same cannot be said of immigration. Increasingly, Singapore's immigration policies focus on establishing and supporting a "Singapore core," which consists of citizens and permanent residents. Changes to job advertising requirements, the need to establish an ability to financially support the hire, and changes to qualifying salaries in the last year have further tightened the immigration flow into Singapore. This is not expected to change in the next 12–18 months.
HOW WE CAN HELP
Our Asia-Pacific immigration team can assist in navigating the landscape and provide recommendations for travel planning. Our services include entry eligibility assessments, quarantine exemption assessments, and related visa/entry approval/quarantine exemption applications.
NAVIGATING THE NEXT.
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CONTACTS
If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following Morgan Lewis lawyers:
Hong Kong
Vivien Yu
China
K Lesli Ligorner
Tokyo
Tomoko Fuminaga
Singapore
Jonathan Tang*
Washington, DC
Shannon A. Donnelly
*A solicitor of Morgan Lewis Stamford LLC, a Singapore law corporation affiliated with Morgan, Lewis & Bockius LLP
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