Prohibited entry goods can still be imported: China’s special quarantine approval

Four things are prohibited from entering China under article 5(1) of the Law on Entry and Exit Animal and Plant Quarantine, and they include two that research institutions need routinely:

• Animal and plant pathogens, including bacterial and viral strains, pests and other harmful organisms
• Animals, plant products and other quarantine material from countries and regions where animal or plant epidemics are occurring
• Animal carcasses
• Soil

Prohibited here does not mean impossible. Where there is a genuine scientific need, an item on that list can be imported under special quarantine approval — a route that exists precisely so that germplasm introduction, seed breeding and biomedical research are not shut out by a rule aimed at biosecurity risk.

GACC announcement No. 209 of 2024, issued on 31 December 2024, refined the scope, the application materials and the timetable. The practical value of that announcement is that the process now has published durations, so it can be planned against rather than merely hoped for.

Regulatory basis

• 《中华人民共和国生物安全法》 — Biosecurity Law
• 《中华人民共和国进出境动植物检疫法》 — Law on the Entry and Exit Animal and Plant Quarantine — and its implementing regulations
• 《外来入侵物种管理办法》 — Measures on the Administration of Invasive Alien Species
• 海关总署 2024 年第 209 号公告 — GACC announcement No. 209 of 2024, on optimising special quarantine approval for entry animals and plants

The application checklist

• The special quarantine approval application form
• For high-pathogenicity or suspected high-pathogenicity animal microorganisms, plant pathogens including strains, pests and other harmful organisms, material from epidemic-affected countries or regions, and soil: an approval document from a provincial or ministerial-level authority or above, or an equivalent-level research project approval
• An ecological and biosecurity risk self-assessment report
• The using organisation’s biosecurity management system and the safety measures it intends to apply
• A signed undertaking to discharge biosecurity responsibilities
• Where an agent files, the authorisation

The second item is the one that determines the timetable, because it originates outside the customs system. A research project approval at provincial or ministerial level is not obtained in the weeks before a shipment.

The approval process, step by step

1. The using organisation or its agent prepares the file, before the prohibited item travels.
2. The application is submitted to the directly-affiliated customs office where the organisation is located.
3. That office reviews the materials and decides whether to accept the application, then notifies the applicant of the time and method of examination.
4. Within five working days, with the applicant or its agent present, customs examines the research and isolation quarantine facilities and the safety measures, on site or by video. It then assesses the risk of introducing disease, the biosecurity risk and the effect on the ecological environment.
5. Where the assessment is satisfactory, GACC issues the quarantine permit within twenty working days of the licensing application being accepted. Where it is not, a written refusal is issued with reasons.

Three conditions that change how the shipment is planned

The permit is single-use. A quarantine permit for prohibited entry goods is valid for one use within its validity period and may not be written off in instalments. A quantity split across two shipments needs two approvals, so the consignment has to be consolidated before the application, not after it.

Facility changes invalidate it. Where the condition of the research or isolation quarantine facilities changes during the validity period, the organisation must apply for special quarantine approval again. The permit attaches to the facility as examined, not to the organisation in the abstract.

Use is supervised after arrival. Once the prohibited item is in, the using organisation remains under customs supervision and must conduct the research in accordance with national rules. It may not be moved elsewhere or put to a different use without customs approval.

Ordinary quarantine permits: two operational details worth knowing

Most consignments in this category do not involve prohibited items, and use the ordinary entry animal and plant quarantine permit through the approval system on the Single Window. Two mechanics of that system regularly surprise people.

The write-off ceiling is 105%. The system calculates the quantity that can be written off against a permit as the applied-for quantity plus an automatic five percent. Cumulative write-offs may not exceed that ceiling. It is a tolerance for ordinary quantity variation, not a licence to over-ship. Write-offs can stop matching: a permit showing unwritten-off status after declaration, or a quantity deducted that does not agree. The fix is to go back to the customs office that accepted the original application, with the declaration and the transport document.

Cancelling a permit is one-way. A permit can be cancelled only while it is issued and not fully used, with the remaining balance no longer needed. Permits that have expired, been fully written off, or have live declarations or write-offs attached cannot be cancelled. Cancellation requires the scanned original of the previously issued permit, with the seal and permit number legible, and customs generally decides within one to two working days. Once cancelled it cannot be restored and the unused balance is void; permits are cancelled one at a time, with no batch function; and the supporting records should be kept for at least a year for later customs verification.

For applications generally, a return for correction usually carries a deadline of about five days. An application can be withdrawn between successful entry into the customs system and the start of approval, and that is the window in which a filing error is cheap to fix.

What this means for a research import

Work backwards from the twenty working days, and add the time needed for whatever provincial or ministerial approval underpins the application. The customs stage is defined and reasonably quick; the stage before it is neither, and it is the one that decides whether a shipment happens this quarter or next.

Facility readiness is the other early item, because the examination looks at the physical conditions and the safety measures rather than at the paperwork describing them. Where an institution’s containment arrangements have changed since a previous import, that alone requires a fresh approval.

We have handled this route for soil samples for university research and for germplasm moving in the other direction, where the approval, not the freight, is the whole of the lead time.