6.1. Shanghai City: purchase of 16.7 tonnes of pangolin scales, mainly from Sichuan, Hebei and Beijing
Shanghai City publishes a relatively large amount of information about permits for purchasing pangolin. If you look up ‘Shanghai City Wildlife Protection Department’, the official website of the Shanghai Greenery and Urban Appearance Management Office, and enter the keyword ‘pangolin’, you can find information on 65 administrative licences from July 2007 to May 2016. Information is given on 11 companies which utilise pangolin (Shanghai Shangyao Huayu Pharmaceutical Co. Limited (formerly Shanghai Huayu Pharmaceutical Co., Limited.); Shanghai Yutiancheng Pharmaceutical Co. Limited; Shanghai Yanghetang Pharmaceutical Co. Limited; Shanghai Wanshicheng National Pharmaceutical Products Co. Limited; Shanghai Tonghanchuntang Pharmaceutical Co. Limited; Shanghai Wotianfu International Trade Co. Limited; Shanghai Qingpu Pharmaceutical Co. Limited; Shanghai Leiyun Shangzhong Chinese Medicine Factory; Shanghai Cambridge Chinese Medicine Co. Limited; Shanghai Hongqiao Chinese Medicine Co. Limited; and Shanghai Dedatang National Pharmaceutical Co. Limited), a zoo (Shanghai Zoo), and three hospitals, (Shanghai Hospital of Integrated Traditional Chinese with Western Medicine; Baoshan District Chinese Medicine Hospital; Shanghai University of Traditional Chinese Medicine Yueyang Integrated Medicine Hospital). It also includes seven enterprises which are located outside Shanghai that use pangolins; they are Sinopharm Lerentang Hebei Pharmaceutical Company Limited, China National Traditional Chinese Medicine Corporation, National Chinese Medicine Stock Co. Limited, Chengdu University Of Traditional Chinese Medicine Haikang Pharmaceutical Company Limited, Sichuan Kelun Natural Pharmaceutical Co. Limited, Shaanxi Weinan Fuman Pharmaceutical Col. Limited, and Sichuan Traditional Chinese Medicine Co. Limited.
Of the 65 public records of administrative licenses relating to the transport, sale or utilisation of pangolin, only 24 included the weight of the pangolin scales, the total weight being 26,503.45 kilograms. It is impossible to know how many pangolins scales are included in the remaining 41 administrative licenses. These 24 administrative licenses only represent 54.5% of all licences, and so the weights of almost half have not been released.
Of these 24 administrative licenses, 12 relate to purchase of pangolin scales, the total weight being 16,704.4 kilograms. This includes 198 kilograms of African giant pangolin scales which Shanghai Wotianfu International Trade Co. Limited imported from Uganda in 2014; 1,920 kilograms of pangolin scales which Shanghai Wanshicheng Domestic National Pharmaceutical Products Co. Limited purchased from Sichuan; and 14,238.2 kilograms of pangolin scales which Shanghai Shangyao Huayu Pharmaceutical Co. Limited (formerly Shanghai Huayu Pharmaceutical Co. Limited) purchased from Beijing, Sichuan, Shaanxi and Hebei. In addition, Shanghai Shangyao Huayu Pharmaceutical Co. Limited provided pangolin scales to at least six other enterprises in Shanghai: Shanghai Tonghanchuntang Pharmaceutical Co. Limited; Shanghai Yutiancheng Pharmaceutical Co. Limited; Shanghai Yanghetang Pharmaceutical Co. Limited; Shanghai Leiyun Shangzhong Chinese Medicine Factory; Shanghai Qingpu Pharmaceutical Co. Limited; and Shanghai Cambridge Chinese Medicine Co. Limited.
As the information of the Beijing, Sichuan and Hebei Forestry Administrations is incomplete, the acquisitions of these Shanghai enterprises cannot be further traced.
6.2. Anhui Province: Mismatch between information that is actively released and information released in response to applications for public disclosure
Between January 2010 and February 2016, the website of the Anhui Forestry Administration featured information relating to the sale and utilisation of pangolins. This confirmed that 10 medical enterprises in the province could trade in and utilise pangolins: Anhui Wansheng Chinese Medicine Company Limited; Bozhou City Hongda Chinese Medicine Technology Co. Limited; Bozhou City Huqiao Pharmaceutical Co. Limited; Bozhou City Yuanmintang Pharmaceutical Sales Co. Limited; Bozhou City Hongren Pharmaceutical Sales Co. Limited; Anhui Huilong Pharmaceutical Co. Limited; Bozhou City Chaofeng Pharmaceutical Sales Co. Limited; Bozhou Shuzhong Pharmaceutical Co. Limited; Bozhoushi Fuwenyuan Pharmaceuticals; and Bozhou City Yongxintang Pharmaceuticals.
In addition, the website also stated that medical enterprises such as Bozhou City Jiahui Pharmaceuticals Co. Limited, Bozhou Traditional Chinese Medicine Factory and Anhui Yatai Pharmaceuticals Co. Limited bought 2,540 kilograms of pangolin scales from Yunnan Province Dehongzhou Ruili Forest Police; Beijing Tongrentang (Bozhou) Prepared Medicine Co. Limited bought 500 kilograms of pangolin scales from Sinopharm Pharmaceuticals Co. Limited; Bozhou City Huqiao Pharmaceutical Co. Limited bought 800 kilograms of pangolin scales from Shaanxi Province Weinan Huayu Pharmaceuticals Co. Limited; China (Bozhou) Shanghai Leiyunshang Traditional Chinese Medicine Factory transported a total of 800 kilograms Shanghai Wanshicheng National Pharmaceutical Products Co. Limited in December 2010 and November 2012; Anhui Yatai Pharmaceuticals Co. Limited transported a total of 1,370 kilograms of pangolin scales to Guangdong Yifang Pharmaceutical Co. Limited in March 2011, January 2013 and July 2014; and Bozhou City Huangshan Pharmaceuticals Co. Limited sold 45.45 kilograms of pangolin scales, which it bought at two auctions, to Anhui Jiren Pharmaceuticals Co. Limited in May 2012.
If the data on sales and transport of pangolin scales is combined, there should be at least 1,715.45 kilograms of pangolin scales remaining within Anhui Province. If all remaining pangolin scales are reported to the SFA, there should be at least 1,715.45 kilograms of pangolin scales in stock.
However, according to the response from the Anhui Forestry Administration regarding stocks of pangolin scales, excepting those held by Anhui Yatai Pharmaceutical Co. Limited which was unwilling to announce its stock, the stock is at least 1,251.05 kilograms: 34 kilograms of pangolin scales held by Bozhou City Yulin Pharmaceuticals Station; 800 kilograms of pangolin scales held by Bozhou City Huqiao Pharmaceutical Co. Limited; 158.5 kilograms of scales held by Bozhou City Huangshan Pharmaceuticals Co. Limited; 124.54 kilograms of pangolin scales in Bozhoushi Yonggang Prepared Pharmaceuticals Co. Limited; and 134 kilograms held by Bozhou City Yuanmintang Pharmaceutical Sales Com. Limited.
Comparing the amounts acquired through two different government information channels reveals a discrepancy, as the two do not tally up. If we compare these with the annual consumption quotas for pangolin materials set by the SFA, we will notice that Anhui Province only applied to use 360 kilograms of pangolin scales in the year 2010-2011.
Such a mismatch of information could lead to a loophole in management and governance, which is not beneficial to pangolin conservation.
6.3. Other publicly available information: Guangdong, Jilin and Shaanxi Provinces
The Guangdong Forestry Administration website features information on seven administrative licences relating to pangolins for the year 2015-16. These relate to the following: the import by Luoding City Chengshan Trade Co. Limited of 500 kilograms of tree pangolin from Congo and of 1,000 kilograms of giant pangolin scales from Uganda, and the sale of 1,000 kilograms of tree pangolin scales to Guangzhou Zhongliang Pharmaceutical Co. Limited; Guangzhou Zhongliang Pharmaceutical Co. Limited sold 50 kilograms of pangolin scales to China Meheco Co. Limited; Zhuhai Xingguang Pharmaceutical Co. Limited used 71.5 kilograms of pangolin scales to produce 1.43 million bottles of Qianlie Tongyu Capsules, and it also used the special marking for pangolin products; Guangdong Yifang Pharmaceutical Co. Limited used 1,500 kilograms of pangolin scales to produce 1.875 million bags of Baoshanjia Peifang Pills, and it also used the special mark for pangolin products.
The reply from Jilin Forestry Administration in response to an application for disclosure of government information was as follows: (1) Between January 2013 and December 2015, Jilin Forestry Administration has approved nine units to utilise and trade in pangolin scales, which include Jilin Changheng Pharmaceutical Co. Limited, Changchun Overseas Pharmaceutical Group Limited, Jilin Tianguang Pharmaceutical Co. Limited, Overseas Pharmaceuticals (Huadian) Co. Limited, Jilin Daojun Pharmaceutical Co. Limited, Diaoyutai Pharmaceutical Group Jilin Tianqiang Pharmaceutical Co. Limited, Changchun Yingping Rheumatism Hospital, Jilin Hongshi Pharmaceutical Co. Limited and Jilin Hengjin Pharmaceutical Stock Company Limited. (2) Between 1 July 2014 and 30 June 2015, five companies – Changchun Overseas Pharmaceutical Group Co. Limited, and Overseas Pharmaceuticals (Zhenlai) Co. Limited, Diaoyutai Pharmaceutical Group Jilin Tianqiang Pharmaceutical Co. Limited, Jilin Hongshi Pharmaceutical Co. Limited, Jilin Hengjin Pharmaceutical Stock Company Limited – used 220 kilograms of pangolin scales to produce TCM drugs such as Jinjia Paishi Capsules, Qianlie Huichun Pills, Liyanling Pills, Rheumatoid Arthritis Pills, and Zhongfeng Zaizao Balls, 610,540 boxes of drugs in total. (3) As of January 2016, Jilin Zixin Pharmaceutical Stock Co. Limited has 7 kilograms of pangolin scales in stock, which came from China National Pharmaceutical Group Corporation. Other medical enterprises do not have stocks of pangolin materials.