What is China’s role in the illicit trade?

China is the world’s largest consumer of pangolin parts, especially the scales, which are used for Traditional Chinese Medicine (TCM).

The depletion of the local species, Chinese pangolins, has led to an influx of both legally imported and smuggled pangolin scales into China from Africa and Southeast Asia.

According to a conservative estimate by researchers, there is a demand for 100,000 pangolins every year to support China’s domestic medicine market. According to the most recent data in 2015, 25,000 kilograms of pangolin scale stock (approximately 50,000 pangolins) were legally released to the market. That means half of its supply would have to come from smuggling from outside the country.

From 2010-2018, China customs and police officials announced that they seized more than 40 tonnes of both live pangolins, plus frozen bodies and scales.  That means at least nearly 100,000 pangolins were killed or captured and then transported to China.

How big is the estimated pangolin population? How many have been seized in recent years?

After decades of hunting, the Chinese pangolin (Manis pentadactyla Linnaeus) has become critically endangered. In 2008, China’s State Forestry Administration estimated that only 25,000 to 50,000 wild pangolins were left in Southern China.

Major seizure cases by the Chinese authorities from 2010-2018:

What is the major use of pangolins?

Pangolins scales are used in TCM, and their meat is eaten as a delicacy. 

China has at least 400 years of history in using pangolin scales for medicine. The scales are believed to be able to treat conditions such as breast milk stoppage, rheumatoid arthritis, sores and boils.

In a show which aired on a Guangdong TV channel, a TCM doctor taught people how to prepare a soup with pangolin scales to enhance breast milk. The program me was removed online because of criticism.

Are there any laws that ban farming, poaching or selling pangolins? What are the penalties?

China has been a member of CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) since 1981.  Many state laws, regulations and court verdicts feature China’s role in CITES and its adherence to protocols and stipulations. According to Chinese Customs, the central government has ordered smuggling crackdowns, demonstrating that the authorities do seem concerned about their international image in terms of global efforts to stem wildlife trafficking  The Chinese authorities seem to take pride in their participation in international efforts to stem out pangolins and wildlife trafficking.

by Sophia Zhang

The “Wild Animal Protection Law”,  which came into effect in 1988, put pangolins as a Class Two endangered wildlife.

Chinese law prohibits the hunting, selling and buying of pangolins unless for scientific studies, species regulation, disease surveillance, or other authorized uses. Cooking and purchase of pangolins for food consumption are also banned. An amendment to the law, enacted in 2016, banned the trading of pangolins on the Internet.

Violators of the wildlife protection laws could face five to ten years of jail time. Under Chinese criminal law, smuggling eight  pangolins is considered as a “severe” crime that could result in 5-10 years imprisonment, while smuggling 16 pangolins could result in  at least 10  years of jail time. 

Allowing the use of pangolins in Chinese medicine has created the biggest loophole in the law.

In the official guidebook on Chinese medicine, pangolins are listed as a permissible ingredient in Chinese medicine. This allows doctors and companies to use them in prescriptions. According to a study by the China Biodiversity Conservation and Green Development Foundation, a government-backed NGO, at least 77 kinds of Chinese medicine use pangolin as an ingredient.

The medical industry can purchase it for medicine after obtaining a license from county-level authorities. The public can also buy legally labelled products.

In 2007, the State Forestry Administration and other ministries issued new guidelines for handling pangolin, presumably to plug legal loopholes. The guidelines made four points: 

1. All kinds of pangolins hunting were banned. 
2. Officials were asked to check the local stock of pangolins scales with the goal of creating a national database. However, the database project has remained opaque and not accessible to the public.
3. Pangolin use should be limited to the quota given by the government, and to products with special official stickers. 
4. The guidelines encourage human-feeding and breeding of pangolins, even though most researchers have found that breeding has failed.

The government encourages individuals and companies to experiment with breeding pangolins, but results are disappointing. According to Chinese media and researchers, no company has been able to meet the standard of success in breeding, which is stipulated as a pangolin who would live more than 10 years in captivity and have a 80% mating rate for three generations

Have there been any actual prosecutions?  Have there been any court cases?

From 2006 to 2019, verdicts of 114 pangolin related criminal cases were posted at Chinese Judgement Online, a government repository of court rulings. Most took place in Yunnan, Guangxi, and Guangdong, three southwestern or southern provinces which share borders with Vietnam, Myanmar, Laos, and Hong Kong, with easy access to international seas.

For example, in the 2016 Shanghai case mentioned in the table above, a criminal named Zhu Lingyun smuggled more than 3,000  kg of pangolin scales (worth  RMB 8.3 million, or about US$ 1.2 million) from Nigeria to Shanghai by shipping. Mr. Zhu then hired a Shanghai trading company using a fake name under fake clearance a shipment of wood. Shanghai Customs found this unusual through machine check. Mr. Zhu was sentenced to 13 years of jail. An accessory named Xu Xuliang was given five years in jail. Mr. Xu and the trading company made RMB 110k in profit, which is about US $ 16k.

By Youqiong Zhang

Who are the people involved in the trade of pangolins? Who they sell the pangolins to and for how much?

A detailed review of the smuggling cases in Guangxi Province shows that just walking across a national border is the most common methods of smuggling.  For example, Dongxing in Guangxi Province shares a long river border with Móng Cái of Vietnam. criminals often take advantage of some small local piers to trade pangolin illegally.

Guangxi officials admitted that its border was one of the most trafficked smuggling lines in the world. While local Customs authorities claimed that they have strengthened patrols at checkpoints in response.

Another detailed review of smuggling cases in Guangdong shows how smugglers take advantage of international waters to avoid inspections. The criminals rent ships and crew members at a very low price from Huizhou or Zhuhai to sail to international waters near Malaysia and Indonesia in the name of shipping ice fish. Their partner from Malaysia or Indonesia will meet them at international sea with tons of pangolins. According to the verdict, criminals gave RMB 7,000-30,000 (US$1,000-$4,000) to each crew member for every movement. They pangolin scale price is given by Forest Authority as evidence at court was RMB 310-1336/kg. That means the total valuation of each trade was millions of RMB. Clearly, an international criminal network was behind this kind of trading.

In Yunnan, the number of disclosed court cases was biggest. The situation there is complicated, as some of the smugglings were mixed with drugs and other animals. Most of the pangolins were transferred through the China-Myanmar border by local people with cars and motorcycles in quite smaller amounts compared with Guangdong. At least one of the criminals was a  Myanmar national. The Customs border checkpoint found most of the cases on a regular basis.

Pangolin scales sales can easily be found online. Here’s an example of RMB 3000/kg of self-claimed “Fried African Pangolin Scale” for sale on the Internet. 

How can you help?

The China Customs hotline: +86-12360 or head office at +86-10-65222882

The China Green Foundation Secretariat: +86-10-88431370 +86-17319453635

Web :http://www.cbcgdf.org/

Email: v1@cbcgdf.org

Fax:+86-10-88431370