United States: COVID Test Required for Travel from China, Starting January 5

Under this new policy, beginning on January 5, 2023, all air passengers two years of age and older originating from the PRC will be required to undergo a COVID-19 test no more than two days before their departure from the PRC, Hong Kong, or Macau, and show a negative test result to the airline at time of departure. Alternatively, passengers who tested positive for COVID-19 more than ten days before the flight can provide documentation of recovery in lieu of a negative test result.

Airlines must confirm the negative COVID-19 test result or documentation of recovery for all passengers before boarding. If the passenger fails to comply with the requirement, the airline must deny boarding to the passenger.

According to the CDC announcement, passengers may meet the testing requirement through a PCR test or an antigen self-test administered by a telehealth service or a licensed provider and authorized by the Food and Drug Administration (FDA) or the relevant national authority.

This new requirement will apply to airline passengers two years and older traveling from mainland China, Hong Kong, or Macau, regardless of nationality and vaccination status – including U.S. citizens and legal permanent residents (LPRs).

The requirement will also apply to individuals traveling from China via third country transit and to passengers connecting through the United States onward to further destinations.

In addition, the requirement will apply to passengers transiting Incheon International Airport, Toronto Pearson International Airport, or Vancouver International Airport on their way to the United States if the traveler has been in China in the last ten days. According to the CDC, these three transit hubs cover the overwhelming majority of passengers with travel originating in the PRC, Hong Kong, and Macau.

Although the CDC announcement does not specify precisely whether those traveling from Hong Kong or Macau via third-country transit are also subject to the testing requirement, this is likely to be the case.

The CDC notes that it will continue to monitor travel patterns and adjust the scope of the requirements as needed.

The new CDC requirement will require travelers from China to engage in additional advance planning in order to ensure they are permitted to board an aircraft for travel to the United States.

In the coming days, the CDC will be issuing a more detailed formal order implementing the new restriction. Fragomen is closely monitoring the situation and will provide updates as developments occur.