An Overview of Pangolin Data: When Will The Over-Exploitation of the Pangolin End? (I)
2018/9/15 18:01:00 本站

Increase the transparency of information. Stop use [of pangolin] in Chinese Medicine

An Overview of Pangolin Data: When Will The Over-Exploitation of the Pangolin End?

--Based on data analysis of government information and suggestions for conservation


China Biodiversity Conservation and Green Development Foundation

July 2016




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(Photo credit: Zhang Mingshu)


In the recent years, due to uncontrolled utilisation and the threat of the illegal trade, it is no longer news that pangolins are close to extinction. According to the most recent IUCN Red List, all eight species of pangolins worldwide are listed as Endangered or above, and the Chinese pangolin and Sunda pangolin are listed as Critically Endangered, only one step away from extinction. Yet, in information published to date, the number of pangolins that are being used commercially remains an unknown quantity.

According to incomplete statistics based on media reports, since January 2015, Chinese enforcement agencies have seized at least 385 live pangolins, 7,024 kilograms of pangolin scales and 3,051 frozen pangolins. This equates to around 10,460 pangolins being harmed by illegal trade the past 18 months alone. According to estimates by the conservation organisation Annamiticus, the number of pangolins seized reflects only 10 to 20 per cent of the true scale of the illegal pangolin trade. From this, it can be inferred that at least 104,600 pangolins have been harmed over this 18-month period, due to the illegal trade in China.

In order to get closer to the reality of pangolin consumption, we made use of official applications channels for disclosure of government information, collecting further data from Chinese government officials and companies. Some of the data collected is presented below.

1. 209 pharmaceutical companies produce 66 types of traditional Chinese medicine that contain pangolin components

We should first find out what types of drug use pangolin, and then where these are produced.

We found out more information about the relevant TCM drugs and pharmaceutical companies through the China Food and Drug Administration’s (CFDA) online database of drug manufacturers. The database includes 77 TCM drugs that contain pangolin, of which 66 have domestic manufacture approval codes that can be looked up in the database; and nine are included in the Pharmacopoeia of the People's Republic of China. The only drug included in the Pharmacopoeia that does not have a domestic manufacture approval code is ‘Fuke Tongjing Wan’, which means it is not produced.

These 66 TCM patent drugs are produced by 209 pharmaceutical companies, which are distributed mainly in northern China. Provinces which have more than 10 of these pharmaceutical companies are, in descending order, Jilin (38 companies), Hebei (18 companies), Liaoning (16 companies), Heilongjiang (13 companies) and Shanxi (11 companies).


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Bar Chart (from left to right): Jilin, Hebei, Liaoning, Henan, Heilongjiang, Shanxi, Inner Mongolia, Shandong, Guizhou, Hubei, Shaanxi, Beijing, Jiangxi, Tianjin, Gansu, Guangdong, Shanghai, Sichuan, Zhejiang, Anhui, Hunan, Jiangsu, Yunnan, Qinghai, Chongqing, Guangxi, Xinjiang

Chart 1: Distribution of pharmaceutical companies by province, autonomous regions and municipality


2. The State Forestry Administration “sentenced” 180,000 pangolins to death in seven years

So where did they get the pangolins to meet the demand for drugs that contain pangolins? How many do they need? What are the differences between the usage approved by the government and actual usage?

Let us first gain a better understanding of the historical data.

Chinese Pangolins (Manis pentadactyla) were once distributed widely in Southern China. According to historical data, pangolin populations were once found in Fujian, Guangdong, Guangxi, Yunnan, Guizhou, Hunan and Hainan. According to incomplete statistics from a Guangdong medicinal materials department, more than 20,000 pangolins were captured every year in the province in the 1960s. The annual catch in Fujian, Yunnan, Guangxi and Guizhou was similar to Guangdong. It is estimated that the annual catch in the remaining areas was between 50,000 and 60,000. In this case, in the 1960s, 170,000-180,000 pangolins were captured every year in China. In the early 1980s, pangolin populations started to decline, and kept dropping dramatically. There was an 80 per cent decline over the following decade. Only 4,029 pangolins were caught in Fujian in 1990. By the late 1990s, the annual catch was only a few hundred kilograms, and most regions had no more pangolins that could be collected.

According to estimates by researchers such as Zhang Li. the annual Chinese demand for pangolins is about 200,000 animals. The ratio of demand for food and medicine is 1:1. It is obvious that the demand cannot be fulfilled by wild resources in China, and stores gathered from the 1960s to present cannot guarantee sufficient remaining stock. Since 1993, China has had to rely on imports from Myanmar and Vietnam. Large quantities have also been smuggled over this period, transported to place like Guangdong and Fujian for sale. Since 2000, due to the restrictions imposed by CITES, trade in all Asian pangolin species for commercial use has been prohibited.

In November 2007, five departments, the State Forestry Administration, the National Health and Family Planning Commission, the State Administration for Industry and Commerce, the China Food and Drug Administration and the State Administration of Traditional Chinese Medicine, jointly published the "Notice on Strengthening the Protection and Management of the Medicinal Products of Saiga Antelope, Pangolins and Rare Snakes" (Forest Protection Notice [2007] No. 242): “According to a national survey of wildlife resources, pangolin populations in China have declined significantly and are now critically endangered.” The document requested that the issuing of special permits for hunting pangolins be stopped, and strict supervision of raw materials from pangolins be enforced. “Use of pangolin materials be restricted to clinical treatments in designated hospitals and TCM drugs, and should not be sold outside these designated hospitals.”

Yet unfortunately, information is presently lacking regarding existing domestic pangolin scale stocks and sources. The State Forestry Administration (SFA) has not yet revealed the actual number of pangolins used or the amounts remaining, or the basis of regulations. We applied to the SFA requesting the official data, as we wanted to gain a better understanding of the products which have been granted a special marking to use pangolin and the companies involved. However, the SFA replied that the pangolins are under second-class state protection, and that information relating to the sale, purchase or utilisation of pangolins and the products thereof must come through the department of wildlife protection under the government of the province, autonomous region or municipality, or other units authorised by these departments, and is not within the remit of the SFA. Therefore, we did not receive any relevant information from the SFA. The official data published by provinces, autonomous regions and municipalities is recorded in chapter 6.

Since 1 March 2008, all TCM drugs and products which contain pangolin scales should display the “China Wildlife Sale and Utilisation Management Special Marking” on the packaging before it can enter circulation. Hereafter, the SFA set annual quotas to determine the amount of pangolin materials that could be used; forestry departments may not exceed these quotas.

Fortunately, these consumption quotas are publicly available. We think that the numbers are shocking.


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Title: Annual consumptions quotas set by the State Forestry Administration relating to stocks of pangolin scales

Provinces (from top to bottom): Beijing, Zhejiang, Shanghai, Jilin, Guangzhou, Liaoning, Yunnan, Sichuan, Jiangxi, Tianjin, Hebei, Hubei, Shanxi, Shandong, Henan, Heilongjiang, Shaanxi, Guizhou, Inner Mongolia, Chongqing, Hunan, Tibet, Anhui, Fujian, Qinghai

(Chart 2: The above data is quoted from the official website of State Forestry Administration)

According to data from 2008-2015, consumption quotas amounted to a total of 186 tonnes, an average of 26.6 tonnes per year. The top five provinces with the biggest consumption quotas were Beijing (19.1%), Zhejiang (14.4%), Shanghai (13.2%), Jilin (7.4%) and Guangdong (7.4%). These provinces represent 61.5% of the total.


In addition, the SFA announced that a total of 716 designated hospitals across China may use pangolin materials; this number included almost all TCM hospitals in the country. It is worthy of note that maternity and paediatric hospitals are excluded from the list of designated hospitals, which means they do not have permission to sell TCM which contains pangolin.

3. [China] imported 14.89 tonnes of pangolin scales in the past 10 years, equivalent to approximately 14,890 pangolins

Although the actual number of pangolin scales used was not announced, but it can be estimated by process of elimination. By subtracting the imported amount from the amount used, we can gain a better understanding of the original stock of pangolins.

In 1994, pangolins were listed on Appendix II of CITES, meaning international trade is regulated. According to the database on the official CITES website, we understand that pangolin scales were imported to China on 10 occasions between 1994 and 2014, involving 10.4 tonnes of Sunda pangolin scales and 3.2 tonnes of giant pangolin scales. In general, all pangolin scales are taken from the wild, and are used commercially. There has been a shift in origin of imports, from South-east Asia to Africa. Malaysia was once the major supplier of pangolins, and Singapore was the place of transit. In the recent years, Uganda and Congo have become the major supplying countries.


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(Table 3: The above data is taken from the database on the official CITES website)