As one of the world’s largest consumers of pangolin products, primarily in traditional medicine, China’s domestic market plays a critical role in the survival of these gentle creatures. However, questions persist about the legality and status of the country’s stockpile of pangolin parts, especially with the recent announcement of a new annual quota of 1 metric ton of pangolin scales for medicinal use — something conservationists warn could perpetuate illegal trafficking.

Earlier this month, China submitted a document to CITES, the global wildlife trade convention, outlining its conservation measures, including using 1 metric ton of pangolin scales annually, equivalent to about 2,000 pangolins. It described this as a “reasonable reduction of consumption.”  

The submission comes ahead of the 78th meeting of CITES’s standing committee (SC78) in Geneva in February. China first announced this policy in a November 2024 notice directing relevant government agencies to comply.

This move contrasts with the international ban on the pangolin scale trade, and continues a recent trend in which China has presented an unclear stance on pangolin conservation. While the country elevated its three native pangolin species to the highest level of national protection, and in 2020 removed pangolin scales from the official list of “raw ingredients” for traditional Chinese medicine (TCM), pangolins are still listed as an ingredient in patent medicine formulas in the official TCM reference book.

Some experts say the new quota represents some progress, as it’s a smaller and more restricted amount than the 25-metric-ton annual quota prescribed from 2008 to 2015. This marks a significant reduction from the peak of legal pangolin consumption in China, which reached 26.6 metric tons (29.32 tons) during that period. 

But the announcement highlights remaining loopholes and questions, which conservationists say undermine efforts to conserve pangolins.

China’s ‘legal’ pangolin scale sources

Decades of exploitation have pushed all eight known pangolin species to the brink of extinction, with conservation statuses ranging from vulnerable to critically endangered on the IUCN Red List. 

All pangolin species were placed into Appendix I of CITES in 2016, meaning their international commercial trade is prohibited. Since then, there’s been no legal international source for China’s imports of pangolin scales. Domestically, the situation is similar: under China’s Wildlife Protection Law, pangolins were classified as Category I state-protected animals, prohibiting their capture from the wild. 

So where is China legally acquiring its pangolin scales from? 

For one, there are the “legal stockpiles” obtained before 2016 from Africa and Asia, according to Yifu Wang, who studied pangolin scale demand for her Ph.D. at the University of Cambridge, U.K. These stockpiles, held by both private and public entities, form the quota and are regulated through permits, Wang told Mongabay by email. She added these stockpiles continue to fulfill the high demand for pangolin scales in Chinese hospitals and pharmaceutical shops.

What’s puzzling for conservationists is the seemingly endless supply from these stockpiles and China’s lack of transparency about the remaining quantities. “We do not know if there is still any left,” said Wang, who continues researching pangolins while serving as an assistant professor at the Chinese University of Hong Kong. 

Erin Chong, a pangolin campaigner with the U.K.-based Environmental Investigation Agency (EIA), echoed concerns about China’s lack of transparency in publicly reporting these stockpiles. China last audited privately held stockpiles in 2006, but since then, “it does not appear that China’s stockpiles are diminishing,” Chong told Mongabay by email.

Chong noted that because the stockpiles are privately held, not centrally managed, and lack provenance reporting, it’s unclear where the scales come from, as China hasn’t disclosed this information. While China has claimed to destroy stockpiles occasionally, it hasn’t published its methods or management systems, she said. 

“The most up-to-date public reporting from China to CITES mentions an unknown quantity of scales and a vague description of its stockpile controls,” Chong said.

Without proper oversight, China’s legal markets and stockpiles “risk becoming a smokescreen for continued illegal trade,” said Olajumoke Morenikeji, West Africa chair of the IUCN’s Pangolin Specialist Group. “The lack of clear information about the size and management of these reserves raises questions about the potential for illegally sourced scales to enter the market under the guise of legality.”

EIA investigations have found “a continued flow of pangolin scales into China, especially through Vietnam,” with most sourced from West and Central Africa, though there’s also a resurgence of Asian pangolin scales.

Following seizures, Chinese authorities have sometimes auctioned off pangolin scales to certified permit holders and pharmaceutical companies, as documented by the EIA in 2013, 2018 and 2019.

Wang confirmed this, attributing it to China’s lack of policy against such sales, something she said she’s advocating to change. “There is no policy in China forbidding the re-sale of seized pangolin scales into the legal market … thus the auction is legal as long as the buyers hold relevant permits,” she said. 

Further obscuring checks and balances, watchdog environmental groups based in China haven’t even been included in policy developments concerning pangolin conservation. “NGOs in China, including TRAFFIC, have not been involved in these discussions with the Chinese government,” TRAFFIC China director Ling Xu told Mongabay by email.

Morenikeji called China’s new pangolin policy alarming, saying it fuels demand that drives illegal poaching and trafficking, further threatening populations in West and Central Africa, disrupting ecosystems, and potentially harming agriculture due to the loss of natural pest control that pangolins provide in these regions.

“China’s newly announced annual quota of 1 ton of pangolin scales for traditional medicine feels like a direct blow to the conservation efforts we desperately need,” Morenikeji said. “By permitting such quotas, the risk of enabling illegal networks grows, jeopardizing the future of a species already on the brink of extinction.”

Mongabay contacted China’s National Forestry and Grassland Administration for comment but didn’t receive a response by the time this story was published. 

CITES’s limitations on domestic trade

CITES is an international agreement designed to ensure the trade in wildlife, including pangolins, doesn’t threaten species’ survival. It issues recommendations to signatory countries, like China, including closing domestic markets that contribute to poaching and illegal trade, and ensuring the destruction or repatriation of seized pangolin stocks after investigations.

However, these recommendations aren’t enforceable in practice, as compliance is ultimately voluntary. While CITES is legally binding for its parties, requiring them to implement the convention, it doesn’t replace national laws or regulate domestic trade, even if it involves Appendix I-listed species like pangolins.

“Domestic trade of CITES-listed species falls out of the scope of the Convention,” CITES said in an email to Mongabay. Referencing a resolution from its 2022 summit, CITES said “pangolin scales should generally be used ‘only for bona fide scientific, educational, enforcement, or identification purposes,’ or be otherwise disposed of.”

For Wang, CITES’s lack of jurisdiction over domestic matters means that directives like “destroy and repatriate” are merely suggestions for what to do with seized pangolin scales. The issue becomes even more pressing as China recently announced plans to expand the global coverage of TCM facilities and services, potentially fueling the demand for supplies such as pangolin scales. Wang said the overall regulatory system “needs to be strong and steady” to prevent illegal products from entering the legal market, while Morenikeji said “China must ensure transparency by proving that its quota only uses scales from pre-existing stockpiles, not freshly acquired scales from illegal sources.”

China’s hits, misses in curbing pangolin trade

China highlighted its pangolin conservation efforts in 2024 through several announcements, including a 2024-2030 action plan announced in March, and policy notices in July and November detailing improvements in legal frameworks, habitat protection, law enforcement, and scientific research. In its January 2025 document, China vowed to “gradually reduce the consumption of pangolin medicine.”

These updates came following CITES decisions on pangolins made during the 2022 summit, including recommendations such as stricter stockpile management, regular reporting to CITES, and removing references to pangolin parts from the official pharmacopeia — measures China says it has followed.

Chong called this “some progress,” but highlighted that China hasn’t adopted at least one of the key CITES recommendations: closing domestic markets. 

“It continues to provide opportunity and demand for illegally sourced scales,” she said. 

Chong also pointed out that while China pledged in its January 2025 document to carry out an inventory of its pangolin scale stockpiles, it has yet to disclose their quantity, provenance or management — only asserting that it doesn’t use illegally obtained stocks or those from unknown sources.

The continued use of pangolins in TCM is in line with China’s Wildlife Protection Law, which, despite upholding pangolin conservation, still allows exceptions for their use in scientific and special purposes, including traditional medicine. Chong and other conservationists said these “legal loopholes” have remained unchanged since the law’s enactment in 2023, and the 2020 revisions to the pharmacopeia still permit pangolin use in processed, ready-made medicines.

Still, China is expected to report on its stockpile management at the standing committee meeting in February and the next CITES summit in Uzbekistan in November this year. Conservationists are calling on China to be transparent, robust and detailed in its reporting, and to adhere to its renewed commitment to fully exclude pangolins from the 2025 edition of its TCM pharmacopoeia.

“The upcoming CITES conference is a chance for China to show genuine commitment by ending new trade and advocating for strict enforcement of pangolin protections,” Morenikeji said.

Banner image: The Philippine pangolin is critically endangered, hunted to the brink of extinction for its scales and meat. Image by Gregg Yan via Wikimedia Commons (CC BY-SA 4.0).

Citations:

Wang, Y., Turvey, S. T., & Leader‐Williams, N. (2020). Knowledge and attitudes about the use of pangolin scale products in Traditional Chinese Medicine (TCM) within China. People and Nature, 2(4), 903-912. doi:10.1002/pan3.10150

Wang, Y., Turvey, S. T., & Leader-Williams, N. (2023). The scale of the problem: Understanding the demand for medicinal pangolin products in China. Nature Conservation, 52, 47-61. doi:10.3897/natureconservation.52.95916

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