American's Response to OP.

"Since there are many changes and a limitless number of variables, we do not accept responsibility for expenses, delays, reroutings or other losses associated to international documentation."

I suppose OP can dispute all CC charges paid to AA. Seems the merchant didn't provide the service OP paid for.

Perhaps .... although using my example and applying the Timatic rules as interpreted by many agents from different airlines, the traveler would have a ticket to a third country, right? That could be an example where the airline would let the pax fly and some of the TWOV advocate crowd believe Chinese immigration wouldn't let the person in.

Disagree as much as you like. If you fly Country A-China-Country A-Country B TWOV doesn't work. If you're flying Country A-China-Country B-Country A TWOV is perfectly fine. That's not rocket science, but apparently too difficult for some AA agents to understand.

Every day, hundreds (if not thousands) of pax use TWOV in China, perfectly fine.

Right back to square one; Japan is not the destination on the OP's ticket, China is.

If I use the destination of China, I get visa required. If I use the destination of Japan, I get the TWOV.

So ... if I'm a gate agent in LAX and a passenger is going to Shanghai for three days and then returning to LAX with a two hour connection at NRT, do you really blame the gate agent for using Shanghai as the destination? And if I push the gate agent to use NRT as the destination, would it be unusual for the gate agent to tell me I'm trying to game the system?

Except that the airlines don't let pax fly in those situations. As reported on the master thread. They manage to correctly identify in those circumstances that the passenger will be doing a HKG-PVG-HKG round-trip.

Given that the gate agent was presented with advice from the Chinese embassy that the itinerary was legal, then yes, a gate agent should have wondered why they were getting an inconsistent result, and should have tried to replicate the embassy advice.

If they were still unconvinced they had the other three options to satisfy themselves (calling AA in China, calling Shanghai immigration, signing an indemnity).

Could we dabate OPs chance at a DOT complaint of being improperly denied boarding? Assuming DOT understands the correct TWOV rules and it is 100% AAgent fault, what would be a typical DOT ruling be?

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I'm sure the agent tried to figure out why the consulate had sent an email saying this was OK which was why it took a while. Of course, we don't know who at the consulate sent the email or the complete text. I suspect it was hardly a senior consular official responding to emails.

The agent, however, was using Timatic. I invite you to use Timatic, and use China as a destination -- United has a good site -- and see what result you get.

Here are my results:


Summary

Conditional, The traveler will need to hold travel documents as detailed below.

Type: Ok
China - Destination Passport

The following regulations apply to children/minors:

Passport not required for children traveling with a parent or guardian if being registered in the passport of the companion.



Type: Notice
China - Destination Visa

Visa required.

****

If you don't like the Timatic results, this is really an issue for IATA.

Doesn't matter - enter Japan or USA and the six day TWOV is shown. The ticket is essentially a ticket from the USA to the USA, right? Depart LAX, transit PVG (as long as depart within 144 hours), transit NRT and arrive back at LAX.

True, China is the destination. And if China is entered as the destination in Timatic, then the TWOV will not be shown. The only way to get Timatic to display the TWOV is to enter Japan or USA as the destination with PVG as the transit point. Fly to Japan within six days and China considers the 144 hour maximum stay in Shanghai as a "transit."

Although China is the destination in the practical sense, it's not the "destination" for Chinese visa purposes as long as the passenger has an onward air ticket departing no later than 144 hours later.

China permits a Transit Without Visa for 6 days in this scenario, and the OP was transiting China for 6 days or less

Won't this be fatal to any DOT complaint? Regardless of how Chinese immigration handles this, how does one persuade the DOT that AA should be penalized because the agent used China as the destination in this scenario.

I personally can't fathom that part either.

Well as the OP already informed AA where the "loophole" was and AA refused to look that up, then...

What DOT complaint? I haven't posted a single thing about DOT complaints in this thread.

My question is how to get AA gate agents to recognize that visiting PVG (and some other Chinese cities) for up to 144 hours is permissible without a visa on certain itineraries. If the agent inputs PVG as the destination in Timatic, no other combination of inputs will result in the TWOV language appearing. Ergo, entering PVG as the destination does not result in valid results concerning the requirement to obtain a visa.