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The British Chamber of Commerce in China submits comments on the 20 Measures 中国英国商会就中国政府优化疫情防控二十条措施提交意见

The British Chamber of Commerce in China has submitted comments to the Ministry of Commerce and the China Council for the Promotion of International Trade on the recently released Notice on Further Optimising the Prevention and Control Measures of the COVID-19 in a Scientific and Precise Manner (hereinafter the ‘20 Measures’). Below is a summary of our comments.


The British Chamber welcomes the Chinese government’s efforts to optimise its prevention and control measures of COVID-19 in order to minimise disruption to people’s life and the economy. Our members were particularly encouraged by the shortening of quarantine times for inbound travels, the cancelling of the flight circuit breaker mechanism and the promise to only require quarantine once for inbound travellers. These adjustments on border policies can further facilitate the much-needed global business travel and people-to-people exchanges, thereby contributing to China’s economic recovery. Meanwhile, domestic control measures, such as cancelling the designation of medium-risk areas and ‘secondary close contacts’, if fully implemented, are also expected to reduce disruptions to society and optimise the use of medical and human resources dedicated to COVID-19 management.


However, two weeks after the introduction of the 20 measures, the initial hope businesses harboured unfortunately seems to be fading. In the meantime, doubt and pessimism have been mounting as the level of uncertainty has increased significantly rather than decreased in any meaningful way. While the central government continues to stress the importance of a targeted and scientific approach to COVID-19 management, and explicitly opposes draconian rules at the local and community level, in reality, the opposite has been happening. We have been seeing an increasing number of people being put under quarantine, entire communities locked down when they should not have been, more businesses ordered to close and cities across China establishing stricter rules for incoming travellers. The goal to achieve zero COVID has clearly outweighed any other concern at the local level, preventing the 20 measures from achieving their intended effects. Over the weekend, although the chamber is encouraged to see the state media including Xinhua and People’s Daily criticise unauthorised lockdowns, only when the messaging drives real changes on the ground, will the public’s confidence in the government’s COVID-19 management be restored.


What is even more worrying is the lack of communication in enforcing new rules by local governments and communities. Some of our members have reported being arbitrarily put under lockdown without any explanation. Others went on business trips after the release of the 20 measures, only to find themselves experiencing issues with local healthcode yet again in their destinations without any clear logic. Some others also see ‘close contacts’ defined broadly, therefore faced with a higher risk of being designated one and required to quarantine during their trips. Confusion and frustration have also increased in the Chaoyang district in Beijing the past two week as many testing sites have been removed while residents are required 24 or 48-hour test results for entering public places. With all these rules contradicting the 20 measures, there also lacks an enforceable mechanism to report them and prevent local governments and communities from escalating their COVID-19 responses.


In order to ensure that the 20 new measures are truly implemented and in a way that allows for the sustainable development of the economy and society, the British Chamber of Commerce in China proposes the following recommendations.



Recommendations to improve implementation of the 20 Measures:


  • Prioritise devising a science-based exit strategy and communicate it clearly with the public. As can be seen in the past week, public frustration on lockdowns and stringent control measures have been growing. It is becoming clear that hard lockdowns are becoming increasingly unsustainable. Therefore, it is more important than ever that the government itself understands how the country moves out of COVID-19.

Science should take the lead as the government decides on the path to be taken. While the concern regarding any approach other than ‘zero COVID’ is well understood, the government does need to look into plausible alternatives or feasible ways to implement the current approach sustainably – most importantly how to protect the demographics most vulnerable to COVID-19 through a range of measures including increasing their vaccination rate.

The government also needs to communicate its strategy transparently with the public in this process so that the nation understands the reasoning and can move forward with a clear direction.


  • Demonstrate consistent and clear position on COVID-19. The Joint Prevention and Control Mechanism of the State Council should identify and correct local measures that run counter to the 20 new measures. Many recent local measures in violation with the 20 measures continue to be rolled out without any consequence. This sends mixed messages, causing certain parts of the population to believe the central government is effectively endorsing those measures, potentially hurting the government’s credibility as well as aggravating uncertainty for the public and businesses. In particular, the government, communities and health officials must:


Ensure consistent implementation of COVID-19 rules across the nation;


Identify causes for the spread of COVID-19 with the support of scientific evidence and adopt measures that are truly effective;


Avoid widespread lockdown and suspension of businesses;


Establish an enforceable mechanism to allow the public to report on draconian local measures and relevant personnel.


  • Communicate with the public including the foreign business community and individuals in a clear, transparent, and timely manner, or else, it risks denting the public’s confidence even further. Clear communication is urgently needed on every level ranging from offering reasons as to why an apartment building is locked down to explaining the grounds on which healthcode is turned ‘abnormal’.


  • Further reduce quarantine time for inbound travellers, improve quarantine facilities and reinstate more international flights. These measures will go a long way to help revive international travel in and out of China. Current entry rules and quarantine conditions, while having been improved further, still fail to significantly boost business executives’ willingness to travel into China from elsewhere. In order to truly encourage such business exchanges, the processes need to be further streamlined and conditions improved including allowing family to quarantine together and provide essential services (e.g. heating in northern cities) at quarantine hotels.


  • Allow international travellers to obtain healthcode in a timely manner so that when they complete quarantine they can travel with certainty within the country. BritCham China members report difficulty acquiring green healthcode to Beijing during their quarantine processes which increase uncertainty and anxiety regarding domestic travel once quarantine finishes.



The British Chamber of Commerce in China comprehends the challenges the Chinese government faces in dealing with the current COVID-19 situation. We want to highlight the importance of following the science, to which we once again call on authorities to implement the new COVID measures with consistency.  British companies continue to see potential in engaging with the Chinese market; they want to see a clear and consistent exit strategy so that the potential of the China market can be realised with confidence and certainty. We stand ready for policy makers to reach out to us, so we can support on successfully implementing COVID-19 measures, and in particular in communicating relevant changes to the business community.














  • 优先制定基于科学的疫情退出策略,并与公众进行明确沟通。从过去一周的情况可以看出,公众对封控和严厉防控措施的忧虑在增加。硬性封控措施变得越来越难以持久。因此,现在最重要的是,政府了解如何才能让全国最终走出疫情。







  • 明确应对新冠疫情的立场。国务院联防联控机制应该发现并纠正地方上违反二十条措施的做法。最近地方上不断出现许多违反二十条措施的做法,却没有任何后果。这向社会发出了不明确的信息,导致部分人认为这种做法实际得到中央政府支持,可能伤害政府的公信力,并且加剧公众和企业的不确定性。尤其,政府、社区和卫生官员需要做到以下几个方面:











  • 明确、透明、及时地与公众(包括外资企业和个人)沟通,否则可能进一步损害公众对疫情防控的信心。各级政府和各社区迫切需要进行明确沟通,包括说明封锁公寓楼的原因,解释健康码“异常”的根据等。


  • 进一步缩短入境人员的隔离时间,改善隔离设施的条件,恢复更多国际航班。这些措施对于恢复出入境旅行有巨大帮助。目前的入境规定和隔离条件虽然有所改进,但对提高其他国家的企业高管前往中国出差的意愿的作用仍然有限。为了真正鼓励更多商务交流,应该进一步简化入境手续,改善隔离条件,包括隔离酒店允许家人一起隔离和提供基本服务(如北方城市提供供暖)等。


  • 允许国际旅客及时取得国内健康码,以保证其结束隔离后,可以在国内出行。中国英国商会的会员向我们报告,在北京隔离期间,及时获取健康码绿码存在困难,这增加了他们隔离结束后在国内出行的不确定性。




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