Regulatory Open Forum

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  • 1.  shipping of laboratory samples to China

    Posted 20-Jul-2023 00:34

    My client wants to ship a few vials of their investigational drug product from the US to a potential licensing partner (consignee) in China.  The samples are for laboratory experiments only; they will not be administered to humans or animals. The World Courier representative in Beijing says that the consignee must obtain an import permit from the Chinese government for the samples to be allowed to pass through Customs.  The consignee seems to think that it will be very burdensome to obtain such an import license. Consequently, the shipment is not proceeding.

    I have emphasized repeatedly that the samples will not be administered to humans or animals.  But the WC rep still thinks we need an import permit.

    In 2014, I coordinated a shipment of the same drug product via World Courier to a different consignee in China, for animal tox experiments, with no particular difficulty.  Much more recently, my colleagues have shipped other chemical samples to China for lab experiments.  As far as I know, those shipments proceeded very smoothly.  i was unaware of any import permits being required.

    Is the World Courier representative's assertion that we need an import permit correct?  If so, how should we proceed to obtain one?  If not, should we switch couriers with the hope of getting better advice?

    Any insights will be greatly appreciated.



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    John Wetzel
    Principal
    Wetzel Chemistry Consulting, LLC
    Albany OH
    United States
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  • 2.  RE: shipping of laboratory samples to China

    Posted 24-Jul-2023 05:14

    Hello John,

    I guess World Courier are correct. There are plenty of changes in Chinese regulations recently so maybe import was affected too.

    This is what I found on the UPS site - https://www.ups.com/ga/CountryRegsPrint?loc=en_US&origcountry=US&destcountry=CN&cat=004002&PrintRegulations=PrintRegulations

    Based on regulation GAC#180 (2019), microorganisms, human tissues, biological products, blood and their products are prohibited from transiting in China.

    Import of Biological (e.g. Microorganism, DNA's abstract, blood sample and etc.) is strictly not acceptable as China is NOT an approved *ISC country or territory.

    Have a good week,

    Olga



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    Olga Peycheva
    Regulatory and Study Start Up Specialist
    Solutions OP Ltd
    olga.peycheva@solutionsop.co.uk
    United Kingdom
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  • 3.  RE: shipping of laboratory samples to China

    This message was posted by a user wishing to remain anonymous
    Posted 25-Jul-2023 09:13
    This message was posted by a user wishing to remain anonymous

    I am having the same problem. Our investigational drug product is not a biologic. The consignee is not communicating what is required and it is still stuck in customs. This is for testing and not being sold, does it still require an import license?




  • 4.  RE: shipping of laboratory samples to China

    Posted 01-Aug-2023 01:08

    Thank you for your reply.  Your problem and mine are the same (chemical sample, only for laboratory use), except that mine has not shipped yet.  If you solve the puzzle, I would be grateful to learn what the solution was.  John



    ------------------------------
    John Wetzel
    Principal
    Albany OH
    United States
    ------------------------------