What makes a requirement binding here
The Drug Administration Law of the People’s Republic of China, in the revision adopted on 26 August 2019 and in force from 1 December 2019. That revision made a structural change practitioners still misread: it abolished the compulsory certification regimes for good manufacturing practice, good supply practice and good clinical practice. From 1 December 2019 the authority stopped accepting applications for, and stopped issuing, drug GMP and GSP certificates; applications already accepted before that date were completed under the previous provisions.
Through the licence and through continuous inspection, not through a certificate. Abolishing certification did not abolish the requirement. The Law obliges manufacturing and trading enterprises to establish and maintain quality management systems and to keep manufacturing and trading in conformity with legal requirements at all times, and it directs the national authority and its provincial counterparts to strengthen oversight through regular and continuing on-site inspection. Compliance became a state to be held rather than a status to be renewed.