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    United States – COVID-19: Negative Test Requirement for Travelers from China

    GMS Flash Alert 2023-001 | January 6, 2023

    As COVID-19 cases have burgeoned in the People’s Republic of China recently, the U.S. Centers for Disease Control and Prevention (CDC) announced on December 28, 2022, that travelers entering the United States by air from the People’s Republic of China (“China”) and the Special Administrative Regions of Hong Kong and Macau after 12:01 AM ET on January 5, 2023, require proof of a negative COVID-19 test prior to boarding their flights.1

    The negative test requirement is also applicable to passengers entering the United States by air via third country transit and to those connecting through the United States to further destinations.

    The test must be taken no more than two days prior to departure and applies to all passengers two years and older, regardless of nationality or vaccination status, including U.S. citizens and legal permanent residents. Travelers also have the option of presenting documentation of recovery from COVID-19 if they tested positive more than 10 days prior to their departure.

    Why this matters

    As the COVID-19 virus continues to arise in different variants around the world, the U.S. continues to take a cautious approach in an effort to reduce the number of infected individuals entering the country and to better track and study the emergence of those variants. Given that the negative PCR test or antigen self-test must be administered by a tele-health service or a licensed provider and authorized by the Food and Drug Administration or the relevant national authority, travelers entering the U.S. from China, Hong Kong, and Macau are advised to plan accordingly and well in advance of their travel.2

    Airlines will be checking for this documentation and information prior to boarding and are instructed to deny those who are unable to provide it.

    Additional Information

    In addition to those entering the United States on direct flights from China, Hong Kong, and Macau, the negative test requirement is also applicable to passengers entering the United States by air via third country transit and to those connecting through the United States to further destinations.

    Furthermore, the aforementioned requirements also apply to passengers transiting Incheon International Airport in South Korea as well as Toronto Pearson International Airport and Vancouver International Airport in Canada if they have been in China, Hong Kong, or Macau in the last 10 days. The rationale for the latter requirement being that the CDC considers those three airports to be the major transit hubs connecting China, Hong Kong, and Macau to the United States via air.

    KPMG Insights

    The new testing requirements mean that travelers affected by the new rules and their employers will need to consider altering their travel plans or submit to additional steps around proving their “COVID-19 negative” status by means of an approved test.

    Employers with employees traveling to/from China, may wish to build in extra preparatory time to complete their testing and/or collect the necessary documents for entry.

    KPMG Law LLP in Canada is tracking this matter closely. We will endeavor to keep readers of GMS Flash Alert posted on any important developments as and when they occur.

    Contacts

    Elizabeth Nanton
    Elizabeth Nanton

    Partner and U.S. Immigration Practice Leader, KPMG Law LLP

    KPMG in Canada

    Alexander Tolic
    Alexander Tolic

    Associate

    KPMG in Canada

    Additional Resources

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    Footnotes

    1 See CDC "International Travel to and from the United States."

    See CDC, “CDC Announces Negative COVID-19 Test Requirement from Air Passengers Entering the United States from the People’s Republic of China” (December 28, 2022). 

    Also see the "COVID-19 Information" webpage on the U.S. Embassy & Consulates in China website at: https://china.usembassy-china.org.cn/covid-19-information/.

    2 See CDC, “COVID-19 Testing: What You Need to Know” (September 28, 2022).

    Disclaimer

    Please note the KPMG International member firm in the United States does not provide immigration or labor law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

    The information contained in this newsletter was submitted by the KPMG International member firm in Canada.

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