I'm getting conflicting information from US CBP and the Chinese Embassy visa section regarding the ABTC. As has been oft cited in this thread, CBP says the card doesn't work as a visa. According to the Chinese US embassy website
4. Holders of Valid APEC Business Travel Card
The APEC Business Travel Card is a substitute of a multiple-entry visa valid for 3 years. A card holder who presents a valid passport whose image and biometric data exactly matches that on the APEC Business Travel Card can enter China multiple times during the validity of the card for a stay of no more than 2 months each time.
http://www.china-embassy.org/eng/visas/zgqz/#3
In an email to the PRC Embassy's visa section, I explained the purposes and details of my upcoming visit (flying into HKG and entering PRC by train in Shenzhen, then flying in country to PEK and PVG) and asked specifically
Please let me know if membership in the APEC program is sufficient to allow us to enter and travel within the PRC, or if a business visa is required.
to which they replied:
Personally, I'd rather see that reply from PRC Border Guard... but has anyone tried to enter mainland China with a US ABTC and no visa? Is there anyway of confirming what the PRC policy is on this? Its entirely possible that the PRC policy on US ABTCs differs from what the CBP has published (especially since the CBP page doesn't look like its been updated since they started issuing cards.)