In 2000, CITES passed a regulation which placed a zero export quota on the four species of Asian pangolins, and banned the capturing of wild pangolins for commercial use. This is likely the direct cause of the change of import origin from South-east-Asia to Africa. In 2016, the Guangdong Forestry Administration permitted Luoding City Chengshan Trading Company Limited to import 500 kg of tree pangolin scales from Congo and 1,000 kg of giant pangolin scales from Uganda.

According to the CITES database, the total weight of these 10 imports was approximately 14.89 tonnes. This means 14,890 pangolins were imported and commercially used, on the basis that each pangolin weighs 5 kilograms and their scales equate to 20 per cent of their body weight.

In addition, none of the imported pangolins included in this data were Chinese pangolins. If these imported pangolin scales were used in production of TCM, then this use was illegal, and violated the standards of the Pharmacopoeia of the People's Republic of China. In the 2015 Edition of the Pharmacopoeia, the description of pangolin is as follows: “this is the scale of the scaled mammal Manis pentadactyla”. This means that only the scales of Chinese pangolins may be used in TCM. Clearly, the Chinese pangolin is close to extinction and cannot meet the demand of the medical market. Therefore it has largely been replaced by other species of pangolin.

According to Liu Xun’s investigations into demand for pangolin materials in the TCM market in Bozhou, Anhui, the sources of medicines containing pangolin on the market today are quite complicated. Chinese pangolin is rarely seen, while many pangolin scales in the market are from Africa and South-east Asia. Sunda pangolin has become the standard product.

Over this same 10-year period, there are eight records of China exporting pangolin scales. The earliest export of pangolin was also the largest, in 1997, when about 500 kilograms of Chinese pangolin scales were exported to the United States. The other seven exports of pangolin scales all derived from seizures. Since 2011, exports of pangolin have been generally for personal use, and no longer for commercial use.

From this collection of data, it is clear that the total imports over 10 years could not even satisfy consumption quota amount set by the SFA for a single year. In this case, the possible sources of the remaining pangolin scales are artificial breeding, smuggling and stockpiles.

4. Most rescued pangolins live for less than 200 days

Traders and scholars are always sharing their opinions on captive breeding: if we can breed pangolins successfully, then we will not have to catch pangolins from the wild, whether domestic or imported, legal or smuggled.

But a fact is often overlooked – what about breeding techniques for pangolins?

In the past 150 years, over 100 zoos and breeding facilities have attempted to breed pangolins. Yet the vast majority of pangolins have died within six months, and very few have survived for more than two years. As pangolins struggle to adapt to the captive environment, their immune system becomes seriously weakened, so they get sick easily. More than half of the pangolins died from hemorrhagic gastric ulcers or pneumonia. In 1983, Shanghai Zoo shared their conclusions regarding feeding pangolins: pangolins’ special eating habits mean that their needs are difficult to fulfill through artificial feeding, and captive pangolins rarely survive for more than six months in China. Causes of death of captive pangolins included: newly-captured pangolins refusing food and starving to death; being forced to eat food that is unsuitable for their digestive systems or perishable, artificial food causing gastrointestinal diseases; and being used to living in dens and unable to adapt to temperature changes at ground level (as they usually rest during the daytime), they got a cold and died of bronchitis.

From 2010 to 2013, not a single one of the 35 pangolins that were seized and rescued in Guangdong survived for these reasons. Most of the pangolins died from digestive problems and unknown reasons, only two survived more than 600 days, while three survived for more than 380 days and 12 lived more than 200 days. In this 25-year period, Guangxi approved four pilot research and feeding units, including Guangxi Botanical Garden of Medicinal Plants, to undertake research into the domestication and captive breeding of pangolins. In May 2012, Guangxi Rare and Endangered Wildlife Rescue Research Centre sent eight pangolins to Guangxi Botanical Garden of Medicinal Plants for breeding, but all of them died within about a month. At present in Guangxi, wild pangolins generally survive for only 100 days in captivity. There has been no news of success in artificial breeding.

5. The number of pangolin breeding companies exceeds the number of government permits issued

Given that artificial breeding has been so unsuccessful, one might assume that very few people would be involved in this business. Yet, we found out from government data that the actual situation is quite the reverse.

Based on our understanding of government administrative licences, we are sure that no permits for breeding pangolins have been issued Jilin, Liaoning, Jiangsu, Fujian, Hunan, Shaanxi or Chongqing. In the remaining provinces, 10 units have administrative permits for breeding pangolins, namely: Xishuangbanna Qingfengyuan Wild Animal Rescue and Breeding Research Company Limited; Yunnan Zhonggan Pangolin Technology Development Company Limited; Guangdong Foshan Nanhai District Yanbu Yuehuiteng Steel Sales Department; Guangxi Shengkai Investment Company Limited; Beihai City Hepu County Xianggu Village Domestication Facility; Guangxi Wild Animal Rescue, Research and Epidemic Monitoring Centre; Jiangxi Zhangshu City Sanling Pangolin Domestication and Breeding Centre; Jinan Zoo Management Office; Qiqihar Longsha Zoological and Botanical Gardens Company Limited; and Shanghai Zoo.

Guangxi Zhuang Autonomous Region is the major source of pangolins for these facilities. Between January and September 2015 alone, Guangxi Wild Animal Rescue, Research and Epidemic Monitoring Centre sent 28 pangolins to Guangzhou Foshan Nanhai Yanbu Yuehuiteng Steel Sales Department and 14 pangolins to Jiangxi Zhangshu City Sanling Pangolin Domestication and Breeding Centre respectively. In addition, Guangxi Shengkai Investment Company Limited sent 11 pangolins to Beihai City Hepu County Xianggu Village Domestication Facility. It cannot be confirmed from data released by Guangxi Forestry Department whether these pangolins were Chinese pangolins.

Meanwhile, wildlife rescue centres in Beijing, Guangzhou, Shenzhen, Zhaoqing, Changsha and Kunming have also kept pangolins.

It must be pointed out that there are certainly more companies than these 10 that are keeping pangolins in China. According to the official website of China Traditional Chinese Medicine Co. Limited, in 2014, 20 companies from seven provinces including Beijing, Shanghai, Guangdong, Guangxi and Fujian, such as the China Traditional Medicine Association Medicinal Ingredients Cultivation Committee, Guangzhou Zhongliang Pharmaceutical Co. Limited., Dongguan City Qingfengyuan Medical Animal Research Centre, along with three companies from Laos, Uganda and Cambodia jointly launched the “Pangolin Rearing Technology Cooperative Development Alliance”. Of these, at least Dongguan City Qingfengyuan Medical and Animal Research Centre has a pangolin breeding site; no corresponding notice of a permit for breeding pangolins is posted on the official website of the Guangdong Forestry Administration of Guangdong, and so there are doubts about the legality of the breeding site.

Clearly, given that breeding techniques are lacking and there are still many breeding enterprises, the question of where these companies are getting their seed stock and whether the animals they are transporting are not in fact taken from the wild or from illegal trade is at least worthy of suspicion. It is even possible that the companies are extracting resources under the guise of artificial breeding, purchasing pangolins caught from the wild or relying on live pangolins that have been seized. Will this captive breeding industry be able to realise its aim of sustainable use of pangolins in medicine? The issue is concerning.

6. Use of pangolins in different regions

The level of transparency of information relating to permits for utilisation of pangolins varies depending on province or municipality, and levels of active acceptance of public monitoring are also different. We include an analysis of this situation in the last chapter of the document.

This chapter explores the known situation by province and municipality.