Resumption of Work and Production in Shanghai – What are the current requirements and conditions?

On May 2, 2022, an announcement was published by the relevant authority in Shanghai regarding the requirements and conditions that companies in Shanghai must meet in order to resume work and production under the current lockdown. We have summarized the key points of these regulations below:


1. How many companies have applied for resumption of work and production on current stage?

Companies that successfully pass the approval process to resume work and production are currently whitelisted by the government. Companies that have been approved to resume work and production are included in the "whitelist". Currently, there are approximately 666 companies on this list. Whether all these companies have actually already resumed work and production is not stated in the list.

2. Which companies are allowed to apply for resumption of work and production at current stage?

The application scope for resumption of work and production mainly includes five categories of enterprises: “urban operation support”, “epidemic prevention materials support”, “important function support”, “continuous production” and “supporting basic support”. Since these objects are only described in very abstract terms, it must be agreed with the authority on a case-by-case basis whether a specific business object falls under the privileged policy.

3. How does the registration process work?

The whole process is roughly divided into 5 steps: preparation, application, inspection, work resumption notice, work resumption.

  • Fully preparation for production, Formulate plan for prevention and control of coronavirus, Fill in the relevant application form.
  • Submit application to competent subdistrict office.
  • Subdistrict office will examine:
    • Responsibility for implementation,
    • Management of classification of premises,
    • Staff management,
    • Logistics management and stockpiling of epidemic prevention materials,
    • Emergency response plan
  • Pass the examination and include the enterprises into the “whitelist”

4. What are the requirements for the personnel organization?

As part of the resumption of work, a process of "closed personnel management" must be implemented. This means that employees must have contact only with colleagues on their permanently assigned shift. In addition, employees must be picked up from and returned to their homes by the company, with no contact with (third) parties outside their shift.

In addition, daily health surveillance and registration of all personnel is required , with antigen testing in the morning and nucleic acid testing in the evening.

5. What are the requirements for the company premises?

The premises of the enterprise must be classified, organized and equipped according to the following different areas: Entrance to the establishment, production areas, recreation areas, restrooms and waste disposal areas, and public areas.

6. How to deal with abnormal or positive cases?

Companies should establish temporary isolated observation areas in proportion to the number of employees.

If an employee's test result is abnormal, this must be reported immediately to the head of the enterprise and the competent authority. The affected persons and immediate contacts must be immediately placed in a temporary isolated observation area. In the event of a positive case, further action must be agreed immediately with the competent authority (closure of the company if necessary).

For any questions or support regarding the application process, please do not hesitate to contact our Schindhelm Shanghai Team.

Dr. Bernhard Heringhaus, Schindhelm Rechtsanwaltsgesellschaft mbH, Osnabrück
Marcel Brinkmann, Schindhelm Rechtsanwaltsgesellschaft mbH, Shanghai