Product labels may be failing to protect pangolins in China

E-commerce sites need not display the China National Wildlife Mark, and there are concerns about where pangolin scales are coming from.

China’s Wildlife Protection Law bans the sale, purchase and use of Class II and Class I protected species, except for “scientific research, captive breeding, exhibition, heritage conservation or other special purposes”. Traditional medicine manufacturers can use pangolin scales under the “special purposes” exception. Image: , CC BY-SA 3.0, via Flickr.

Late last year, the China Customs Anti-smuggling Bureau received an award for arresting numerous wildlife criminals and its participation in global anti-smuggling operations. The award was presented in Panama at the 19th Conference of the Parties to CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora).

The bureau’s work includes fighting pangolin smugglers. In 2020, it was involved when police in the Guangxi capital of Nanning confiscated 125 kilograms of pangolin scales and made 18 related arrests. In 2021, police in Zhuhai, Guangdong province, confiscated almost 8 tonnes of pangolin scales.

Yet the smuggling of scales continues.

In fact, pangolins are the world’s most trafficked mammal, according to a report from the UN Office on Drugs and Crime. Between 2014 and 2018, the quantity of pangolin scales seized rose tenfold, up to the equivalent of 141,000 pangolins per year, the report found. The scales are mostly bound for traditional medicine use in China and Southeast Asia.

A recent report from Global Initiative, which monitors transnational organised crime, found that use of the China National Wildlife Mark is not being properly enforced online: 90 per cent of online listings for medicines containing pangolin scales are not displaying the special label, meaning consumers cannot make an informed choice.

How are pangolins protected by law?

Pangolins already receive the highest levels of international protection. In 2016, CITES added all eight species to its Appendix I, meaning a complete ban on the commercial international trade in pangolin and pangolin products, including medicines.

China too has been toughening up on protections. In 2020, it shifted all Asian pangolin species (the Chinese pangolin, Sunda pangolin and Indian pangolin) from Class II to Class I protected status. That means the pangolin has the same legal protections as the giant panda, with tough punishments for poaching and most types of trading.

A Xinhua report found that tougher law enforcement and better public awareness has led to decreased demand for illegal use of pangolins as food and ornamentation. But there is still strong demand for uses deemed legal under Chinese law, such as in medicine.

China’s Wildlife Protection Law bans the sale, purchase and use of Class II and Class I protected species, except for “scientific research, captive breeding, exhibition, heritage conservation or other special purposes”. Traditional medicine manufacturers can use pangolin scales under the “special purposes” exception.

The law also requires those products to display labels to ensure traceability. Since 1 March 2008, to be sold legally, all medicines and products containing pangolin scales have had to display the China National Wildlife Mark (CNWM) on their retail packaging.

The label has four key functions: to inform consumers that medicine contains ingredients from protected species; which species those are; that they have been legally obtained; and how they were obtained.

Between April and October 2021, Global Initiative gathered data on adverts for products containing pangolin – including medicines and pangolin wine – on over 100 online platforms, including major e-commerce sites, Taobao and The study found that only 9 per cent of 884 listings displayed a CNWM label.

Over half of all the listings were on the websites of “agents”: intermediaries offering medical or healthcare services, such as doctor consultations, which are not bound by the same rules as manufacturers or sellers. Rather than sell medicines, those websites make recommendations based on users submitting their symptoms, and provide links to sites where medicines can be purchased.

Actual e-commerce platforms are better at displaying the necessary labelling, doing so twice as often as agent websites. However, none of the 17 listings found on had CNWM labelling, while some on Alibaba’s 1688 B2B platform risked breaking the ban on international trade by offering overseas shipping.

Regulations require pangolin-derived medicines to display both a CNWM label and a National Medical Products Administration (NMPA) code. The study found 81 per cent of listings showed the NMPA code, which is issued after the administration deem a product “safe, effective and quality-controlled”. But there is no requirement for ecommerce platforms to display CNWM labels.

Alastair MacBeath, an analyst with Global Initiative, says consumer awareness of food and drug safety issues has been increasing and so people are more likely to look for the NMPA code. But retailers and consumers know little about the laws covering wildlife products.

That tallies with a 2020 report which found those working in traditional medicine had poor awareness of the legality of pangolin scale products, particularly sellers at the end of the trade chain. There was also a lack of awareness among the general public.

Professor Lixing Lao, president of the Virginia University of Integrative Medicine, told China Dialogue that regulations requiring pangolin-derived medicines to carry the CNWM were jointly issued by five agencies, including the National Medical Products Administration and the State Forestry Administration (now the National Forestry and Grassland Administration). It remains unclear which of the agencies enforce the regulations, and training for those working in the sector has been inadequate, Lao added.

Opaque stockpiles

Controversy exists over the labelling system itself. As explained above, one of the purposes of the CNWM label is to tell consumers that wildlife-derived ingredients in medicines have been obtained legally. There are only two legal ways for traditional medicine makers to obtain pangolin scales: from official government-monitored stockpiles, and from pangolin breeding centres.

But despite government support, all attempts to breed pangolins in China have failed. So, in practice, the only legal source of pangolin scales is government-monitored stockpiles.

James Toone, a senior campaigner with the Environmental Investigation Agency, a UK-based organisation, explained that China does not yet have a nationwide system for managing stockpiles of pangolin scales. Instead, private holders register their stocks. In 2006, all individuals and private companies holding stocks of pangolin scales had to report the quantity and dates of purchase to local wildlife authorities. These were then required to inspect and audit those stocks and report upwards to the national wildlife authorities.

But the actual size of those stockpiles is unclear. Up to 2016, the State Forestry Administration would issue an annual cap on the number of pangolin scales to be traded. That averaged around 26.6 tonnes between 2008 and 2015, or a total of 186 tonnes. The SFA stopped publishing that data in 2016.

Information on how many legal stockpiles there are, or on the quantities of pangolin scales that hospitals and traditional medicine makers request, is not made public. The lack of transparency and oversight of stockpiles of pangolin scales means illegally obtained scales may be laundered into supplies, setting conservation efforts back.

In 2021, medicine firm Sanhe Pharmaceuticals, was found to have bought 9.89 tonnes of pangolin scales illegally between 2016 and 2018. A single pangolin yields 400–600 grams of scales, so those purchases of almost 10 tonnes meant around 20,000 pangolins had been killed. According to a Caixin investigation, the company forged sourcing documents for the scales and bribed officials in order to get approval for two clearly flawed applications for use of pangolin scales.

Stronger oversight and traceability

The CNWM labels are the most reliable way for consumers to check if the pangolin-derived ingredients in medicines they buy come from legal channels. If that information isn’t available from e-commerce platforms, they cannot make an informed choice. Global Initiative recommends Chinese authorities strengthen the CNWM system, requiring it to be shown on online product listings so consumers can see the environmental impact of their choices.

Worth noting is that in May last year the National Forestry and Grassland Administration produced a consultation draft of regulations for labelling products derived from protected species, including an IT system which would align with CITES and other international schemes. This would allow for accurate traceability and annual publication of statistics on use of the labels.

Protecting pangolins isn’t just the job of police and customs officers. A properly functioning labelling system for pangolin-derived products is also crucial.

This article was originally published on China Dialogue under a Creative Commons licence.

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