Hainan Lecheng: what the pilot zone allows, and what the rules say about taking medicines out

Lecheng is a designated zone in Hainan where licensed institutions may use certain medicines and devices that are approved abroad but not yet registered nationally in China. Under a 2022 measure, patients of those institutions may take a reasonable quantity of certain licensed medicines out of the zone for their own continued use. It is narrower than it sounds, and it runs entirely through the treating institution.

Includes a note on what we could not verify
Aerial view of the Sanya coastline in Hainan province2022take-out rules
in force since

1. What the zone actually is

The Boao Lecheng International Medical Tourism Pilot Zone is a defined area in Hainan province operating under arrangements that do not apply elsewhere in mainland China. Its central feature is a narrow exception to national drug and device registration.

The national policy framing was restated in March 2026, when nine ministries led by the Ministry of Commerce issued measures on promoting travel service exports and inbound consumption. Article 10 of that document provides for:

Policy text, 商服贸发〔2026〕39号, Article 10 (translated)

"Give play to the demonstration role of the Hainan Boao Lecheng International Medical Tourism Pilot Zone. Permit clinically urgently needed drugs (excluding vaccines) and medical devices that are marketed abroad and for which no product of the same variety has been approved for registration in China to be used by medical institutions within the zone. Permit patients of medical institutions within the zone to take a reasonable quantity of imported medicines for their own use out of the pilot zone."

Three limits are visible in that sentence alone, and they are easy to miss on a first reading: clinically urgent need, no equivalent already registered in China, and use by institutions within the zone. Vaccines are expressly carved out.

2. What "licensed access" means in practice

The Chinese term usually rendered as "licensed" or "specially permitted" medicines and devices describes products cleared for use inside the zone under this exception, rather than registered for the national market. Several consequences follow.

  • Access is clinical, not commercial. The route is: you become a patient of an institution in the zone, a physician there determines the product is appropriate for your case, and use proceeds under that institution's arrangements. There is no counter at which a product is sold to a visitor.
  • The catalogue is specific and it changes. Which products are available at any given time is determined by the zone's arrangements and by which institutions have brought them in. This is not a stable list you can plan around a year ahead.
  • Registration status is unchanged elsewhere. A product usable inside Lecheng is not thereby approved for use in the rest of mainland China, and Chinese arrangements have no bearing on its legal status in your own country.

That last point deserves emphasis for anyone travelling. Whether you may lawfully bring a particular medicine into your own country, and in what quantity, is governed by your country's rules, not by China's. This is a question for your own authorities before you travel, not after.

3. Taking medicine out of the zone

This is the provision that draws the most interest and is the most widely misunderstood.

Hainan's drug regulator issued an interim measure in 2020 permitting patients to take a small quantity of clinically urgent imported medicine out of the zone on discharge. That first version covered oral forms only. In August 2022 the Hainan Provincial Medical Products Administration, together with the provincial health commission, issued a replacement, the Administrative Measures for Taking Out and Using Clinically Urgently Needed Imported Drugs in the Boao Lecheng International Medical Tourism Pilot Zone: which made two substantive changes.

2020 interim measure2022 measure (current basis)
Dosage formsOral onlyOral, topical and subcutaneous injection
SupervisionPrior approvalFiling-based
QuantityA small amount, for the patient's own use onlyA reasonable quantity, for the patient's own use only
Who it applies toPatients of medical institutions within the zone. Not visitors, not third parties

Note what did not change. Both versions restrict this to the patient's own use. Official commentary on the 2022 measure describes its purpose as balancing medical safety against genuine need, and specifically as preventing licensed medicines being bulk-purchased, sold on, or given away to others.

Why that restriction matters to you

"For the patient's own use" is not decorative wording. It is the boundary of the entire arrangement. Obtaining medicine for someone else, carrying it on behalf of another person, or onward transfer of any kind falls outside it.

If an intermediary offers to obtain, collect, carry or post these medicines for you, they are proposing to operate outside that boundary. We do not do this, and we would suggest treating any offer to do so as a reason to stop the conversation.

4. What we could not verify

We think it is more useful to tell you where our information ends than to present a confident account with soft parts hidden inside it. Everything above is drawn from the policy text and from official summaries. The following, we could not confirm against a primary source, and you should not plan around it without checking directly.

PointStatus
The exact filing procedure: which forms, who submits them, how long it takesNot verified. The measure is filing-based, but we have not confirmed the operational steps from the full text
How "reasonable quantity" is determined in practiceNot verified. Chinese industry press has reported that, following refinements in 2025, a patient may take up to three months' supply and then return for review. We have not confirmed this against the measure itself. Treat it as unconfirmed
Follow-up and traceability obligations on patientsPartly. Reporting describes a traceability platform and periodic upload of medication records by patients. We have not verified the detail
Which specific products are currently availableNot verified, and changes. Only the institution can tell you this for your case
Whether any of this applies to non-resident foreign patients differentlyNot verified. Worth asking explicitly

5. Four things this is not

  1. Not a pharmacy or a purchase channel. You cannot travel to Hainan and buy an unregistered medicine. Access follows a clinical decision made by an institution that has taken you on as a patient.
  2. Not a route around your own country's rules. Whether a medicine may lawfully enter your country, and in what quantity, is your country's question. Nothing in the Chinese arrangement addresses it.
  3. Not a guarantee that a particular product is available. The catalogue is specific, institution-dependent and subject to change.
  4. Not something an agency can arrange for you. Any intermediary offering to obtain or carry these medicines is offering something outside the rules as written, and outside what we will ever do.

6. What to ask the institution

If your situation genuinely points here, these are the questions worth putting directly to an institution in the zone, in writing, before making any travel plans.

  • Is the specific product available at your institution at present, and under what conditions?
  • What clinical criteria would I need to meet, and what records would you need to see first?
  • If treatment continues after discharge, is this product within the dosage forms eligible to be taken out of the zone?
  • What is the filing procedure, what quantity would be involved, and what would I be required to do afterwards, follow-up visits, reporting, traceability records?
  • What are the total costs, and how are they billed?
  • Do you have experience with non-resident foreign patients, and does anything differ in that case?

Separately, and before any of the above: ask your own country's medicines regulator or customs authority whether the product may lawfully be brought in, and in what quantity. It is the question most likely to change the answer, and the one most often left until last.

What this guide does not cover

  • Whether any particular medicine is suitable for you. That is a clinical judgement for a qualified physician who has reviewed your records.
  • The current catalogue of available products, which changes and is institution-specific.
  • Import rules for your own country, which are set by your own authorities.
  • Medical devices, which fall under related but separate arrangements.
  • Costs, which are set by the institutions.

NOTES AND SOURCES

The policy text quoted in section 1 is Article 10 of the Policy Measures on Promoting Travel Service Exports and Expanding Inbound Consumption (商服贸发〔2026〕39号), issued 16 March 2026 by the Ministry of Commerce together with eight other departments, published text. The translation is ours.

The 2022 measure described in section 3 is the Administrative Measures for Taking Out and Using Clinically Urgently Needed Imported Drugs in the Boao Lecheng International Medical Tourism Pilot Zone, issued by the Hainan Provincial Medical Products Administration together with the Hainan Provincial Health Commission in August 2022, replacing a 2020 interim measure. Summary published by the National Development and Reform Commission, 22 August 2022, which records the expansion of dosage forms to oral, topical and subcutaneous injection, the move from prior approval to filing, and the aim of preventing bulk purchase, resale and transfer of licensed medicines.

Items listed in section 4 as unverified are drawn from Chinese industry press and legal commentary rather than from primary regulatory text, and are identified as such deliberately. Where this page is updated, the date at the top will change.

Ask us what we don't know

Section 4 is the honest edge of what we could confirm. If your question sits in there, say so, we'll tell you who can answer it rather than guessing on your behalf.

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