Due to the pandemic, a foreign employee now needs a PU letter to apply for a PRC visa to enter China in addition to complying with the usual visa and work permit application process. A PU letter is an invitation letter issued by the local district government ('PU' refers to "ptng" which translates to "ordinary" as they apply to ordinary passport holders).

Entry Requirements for Foreign Employees and Their Dependants

An application for a PU letter for a foreign employee and their dependants has to be made by an employer to the local Foreign Affairs Office. To issue the PU letter, the local Foreign Affairs Office will need to have received the foreign employee's work permit notice application. There may be varying local district requirements to obtain a PU letter but in general it can take around two months to process. With the work permit notice and PU letter, the foreign employee can apply for their visa to enter China.

In order to control the number of COVID-19 cases, the government is closely scrutinising applications for PU letters. Whilst some employers may have managed to secure PU letters for their employees on an exceptional basis, the PRC government suspended PU letter application for dependants since late last year.

However, dependents of foreign employees may seek an exemption from the requirement to obtain a PU letter if they can show proof that they have received a vaccine manufactured produced by China (e.g. Sinovac, Sinopharm).

Special requirements on applying the PU letter

As the PU letter is issued by the local government, the requirements to apply for a PU letter may vary across the districts. We understand that a district government recently required employers to provide information on the number of employees who are vaccinated in their PU letter application in order to make sure that the employer complies with their health and safety obligations relating to COVID-19. To comply with this requirements, we have seen employers carrying out an internal autonomous survey to provide an estimated number of vaccinated employees for the purpose of the PU letter application.

Employers will need to keep an eye out on the changing immigration rules and restrictions in bringing their foreign employees into the PRC. Where employers are collating information on vaccinations in order to fulfil a condition of applying for a PU letter, they will also need to comply with data privacy requirements.