Biological products can enter China through five cities, and no others

Most cargo can enter China wherever it is convenient to land it. Medicines cannot. Import is restricted to designated ports, and for two categories the restriction is severe enough to determine the whole logistics design before a carrier is chosen.

• Ordinary and special medicines — nineteen cities, plus a set of named ports including Suzhou Industrial Park, Zhengzhou Airport, the airports at Jinan, Changsha, Shenyang, Wuxi, Hefei and Shijiazhuang, and the ports of Jiangyin, Taizhou and Zhongshan. The nineteen cities are Beijing, Tianjin, Shanghai, Dalian, Qingdao, Chengdu, Wuhan, Chongqing, Xiamen, Nanjing, Hangzhou, Ningbo, Fuzhou, Guangzhou, Shenzhen, Zhuhai, Haikou, Xi’an and Nanning.
• A drug being sold in China for the first time — four cities only: Beijing, Shanghai, Guangzhou and Chongqing.
• Biological products — five cities only: Beijing, Shanghai, Guangzhou, Chongqing and Chengdu.

Export is different: there is no port restriction on exporting medicines from China.

The practical consequence is that a first shipment of a biological product has five possible entry points in a country of that size. If the intended distribution centre is not near one of them, the inland leg is part of the regulatory design rather than an afterthought. It also means the familiar reflex — route to whichever airport has the best capacity this week — does not apply.

Regulatory basis

• 《中华人民共和国药品管理法》 — Drug Administration Law
• 《药品进口管理办法》 — Measures for the Administration of Drug Imports
• 《进口药材管理办法》 — Measures for the Administration of Imported Medicinal Materials
• 《蛋白同化制剂、肽类激素进出口管理办法（暂行）》 — interim measures on anabolic agents and peptide hormones
• 《麻醉药品和精神药品管理条例》 — Regulations on Narcotic and Psychotropic Drugs

The customs clearance note, and why the declaration must mirror it

Imported medicines clear against an Imported Drug Customs Clearance Note — the Q certificate — issued by the drug regulator. It is printed centrally in four copies: the first and second are retained by customs for release, the third goes to the importing company, and the fourth to the port drug testing institute.

The declaration must agree with the clearance note strictly. This is a document-matching exercise rather than a judgement call, and it is where avoidable delays originate.

Applications run through the Single Window at singlewindow.cn: log in with the enterprise account or IC card, then Port Enforcement Declaration → Regulatory Certificates → Imported Drug Customs Clearance Note, which opens the drug and medicinal material import filing page. From there, the inspection application form — drug or medicinal material — is completed, supporting credentials are uploaded, and the application is submitted.

Active pharmaceutical ingredients: filing applies either way

An API import requires a filing with the port drug regulator whether or not the substance appears on the imported drug catalogue. This catches companies who check the catalogue, find nothing, and conclude that no formality applies.

Two routes that are lighter, and the line you cannot cross

Processing trade. Where APIs and medicinal materials are imported under processing trade with both ends outside China, they are exempt from import filing and port testing. The compliance boundary is absolute: goods imported this way, and the products made from them, may not be diverted to the domestic market. Where genuinely exceptional circumstances prevent export, the goods are handed to the local drug regulator for disposal — not sold locally, not written off.

Bonded warehouses and special customs supervision areas. Medicines moving from overseas into a bonded warehouse, bonded zone or export processing zone are exempt from import filing and port testing. The exemption is a function of the goods not having entered China proper, so it reverses on the way out: taking them out of the zone into the domestic market requires the filing and port testing under the ordinary rules. A plan built on the inbound exemption without accounting for the outbound obligation has simply moved the work later.

A recent change worth knowing: dual-use food and medicinal substances

From 3 December 2025 a pilot applies classified supervision to thirty substances used both as food and as medicine — clove and liquorice among them — on the pilot list.

The mechanism is that the declared use decides the documentation. Where such a substance is imported for a non-medicinal purpose, typically food use, the Imported Drug Customs Clearance Note is not required. In exchange, the importer undertakes not to change the use of the goods and not to sell them to anyone who will use them for a purpose other than the one declared.

For a trader importing liquorice for a food application, that removes a substantial formality. It also creates an obligation that survives delivery, and the undertaking is enforceable against the importer rather than against the buyer who diverted the goods.

Personal imports

Medicines carried or posted in for personal use must genuinely be for the individual’s own treatment; sale and resale are prohibited. Import is against a valid doctor’s prescription, in a reasonable quantity, and the prescription cannot be used more than once.

What decides the plan

Three questions, in order, before anything is booked:

1. Is the product a biological product, or a first sale in China? That answer produces a list of five or four cities, and everything downstream follows from it.
2. Does the import route qualify for one of the lighter treatments — processing trade, or a bonded area — and if so, is the eventual exit from that treatment accounted for?
3. Is a clearance note required at all, or does the declared use take the goods outside the drug regime, as the dual-use substances pilot allows?

Get those three right and the freight decision is ordinary. Get the first one wrong and the consignment is at the wrong airport with no lawful way to enter.