International media such as the BBC, The Guardian, CNN and many others have this week reported that the Chinese Government has removed pangolin scales as an ingredient from the latest edition of its traditional Chinese medicine (TCM) pharmacopoeia.
However, the story is not as straightforward as that and, while the Government’s action appears to be a step in the right direction, questions remain.
The country’s TCM pharmacopoeia is a compendium of traditional and Western medicines.
While the Government appears to have removed endangered pangolins from a list of key raw TCM ingredients, it is not yet clear whether pangolins have also been removed from a separate section of the pharmacopoeia as an ingredient in approved patent medicines.
Pangolins are the most trafficked mammal in the world and their scales are in high demand for use in TCM.
Despite consumption of pangolin meat being officially banned in China, licensed hospitals and pharmaceutical companies have been permitted to use pangolin scales in traditional medicines – a practice regarded as a major driver in the transnational trafficking of pangolins from across Africa and Asia into China.
If approved patent medicine formulae in the pharmacopoeia containing pangolin have not been removed or amended, it would mean the pharmacopoeia would continue to promote and legitimise medicinal use of pangolins.
This has happened before – neither leopard bone nor bear bile are now included in the ‘key ingredients’ section of the pharmacopoeia, yet are still listed among ingredients for patent medicines and so their legal commercial use continues.
In China, legal trade in medicinal products is not always restricted to ingredients and patent medicines listed in the pharmacopoeia; EIA has documented products in legal trade which list leopard bone as an ingredient and which are not included in the official directory.
These questions need to be clarified and backed up by official policy announcements before we can celebrate a total ban on China’s domestic trade in pangolins.
However, the move is being interpreted as an acknowledgement from China of the need to address the use of pangolin scales in TCM to protect pangolins in the wild.
The Government has also recently increased the formal domestic protection of its three native pangolin species – Chinese, Sunda and Indian pangolins – from second class to first class special state protection, the highest form of protection under national legislation.
This uplisting does not automatically mean that domestic trade in these species is completely prohibited since exemptions allowing their use in TCM could still apply.
As per existing Chinese Government notices, the other five non-native Asian and African species should already be treated as first class special state protection since they are on Appendix I of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
The uplisting does mean that penalties for wildlife crime involving China’s native pangolins could increase. Obtaining a legal license to collect wild pangolins could also become more difficult since it would require the approval of the central wildlife conservation department (i.e. the National Forestry and Grasslands Administration) instead of provincial forestry departments.
Chris Hamley, EIA Senior Pangolin Campaigner, said: “The latest news from China on the strengthening of domestic pangolin protections is a positive result in the ongoing global effort to end the trafficking of pangolin scales.
“However, EIA would like to see these latest moves backed up by further action and official announcements to ensure that Government permits will no longer be issued for the production and sale of medicines containing pangolin scales and that existing pangolin scale stockpiles will be destroyed.”
EIA remains concerned that other threatened species are still being legally used by companies to make TCM products, such as leopards whose bones are used to make pills and wine.
Aron White, Wildlife Campaigner & China Specialist, added: “It is disappointing that authorities have not taken this opportunity to also unequivocally end official promotion of the use of leopard bone in TCM – the reasons for removing pangolins from the state pharmacopoeia apply to leopards as well.”
这种漏洞先例可循 — 虽然中药药典的原材料部分中没有包括豹骨和熊胆，但仍被列为中成药物的成分之一，因此它们的合法商业用途仍然存在。
环境调查署深表关注对于仍被药制公司合法地生产入药的受威胁物种，如豹骨被制成药丸和药酒之问题。 野生动植物项目主任和中国专家Aron White补充说：「令人遗憾的是，即使豹符合了所有穿山甲从药典中被删除的条件，中国当局却没有利用这次机会明确地终止豹骨 在中药的使用和推广。 」