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Legal petition urges US to certify that China’s pangolin trade violates wildlife treaty

                                Certification could result in ban on wildlife imports from China

WASHINGTON: Conservation organisations filed a legal petition today (6 August) urging the US secretary of the Interior to formally certify China for illegally trading in critically imperilled pangolins.

If certification under the Pelly Amendment is granted, the US Government can sanction China, including banning all wildlife imports from the country.

Pangolins are the most heavily trafficked mammals in the world. These scaly mammals are consumed in China as a luxury meat and pangolin scales are used in traditional Chinese medicine. Despite recent actions by the Chinese Government, legal exemptions and poor enforcement allow continued pangolin trade.

“Pangolins face imminent extinction, yet the Chinese Government continues to promote pangolin scales in the traditional Chinese medicine trade,” said Sarah Uhlemann, international program director at the Center for Biological Diversity. “If we want these odd and adorable creatures to survive, China must act now. Certification by the US would be the wake-up call China needs.”

Since 2017, the Convention on International Trade in Endangered Species (CITES) has banned the international commercial trade in all pangolins. Yet according to the United Nations, pangolin seizures have increased tenfold since 2014. The size of individual seizures — including a record-setting seizure of 14 tonnes of scales in 2019, representing about 36,000 individual pangolins — has also increased.

“Pangolins are the most trafficked mammal in the world and China is the primary source of demand for pangolin scales,” said Nick Fromherz, senior attorney at the International Animal and Environmental Law Clinic of Lewis & Clark Law School. “While China has taken token steps to address the pangolin crisis since the COVID-19 outbreak, these steps are insufficient. Both the United States and China need to show leadership on this issue and do more to protect pangolins and end illegal trade.”

More than 70 per cent of recent pangolin seizures are destined for China, with most other seizures destined for Vietnam, a key transit country to the Chinese market. In China, pangolin scales are legally sold and used in traditional Chinese medicine; they are marketed to increase blood circulation and lactation.

“The existence of a legal market for pangolin scale medicines in China is undermining the effectiveness of CITES and providing an opportunity for transnational criminal networks to profit from illegal trade,” said Chris Hamley, a Senior Campaigner at the Environmental Investigation Agency UK (EIA).

“The global illegal pangolin trade is rapidly devastating pangolin populations across Africa and Asia. This is driving corruption that undermines rule of law and contributes to weak governance and insecurity in source and transit countries. With a continued intransigence from the Chinese Government on the issue, all possible instruments should be utilised to ensure we see an end to the demand that is fueling global pangolin trafficking.”

In 1993, President Clinton used the Pelly process to certify and ban all wildlife imports from Taiwan for its rhino trade, which violated CITES. Taiwan promptly closed its domestic rhino market.

Pangolins have been identified as a potential, intermediary host of the coronavirus causing the current COVID-19 pandemic. In response, the Chinese Government announced a ban on the trade of terrestrial wildlife for consumption as food, in addition to legal protections for pangolins and the purported removal of pangolin scales from the Chinese government’s official Pharmacopeia, a reference guide used in traditional Chinese medicine.

Today’s petition says these changes don’t go far enough: Chinese law continues to permit the distribution, sale and consumption of pangolin scales and pangolins remain a listed ingredient in eight medicines in the country’s Pharmacopeia.



  • Chris Hamley, Environmental Investigation Agency UK,
  • Sarah Uhlemann, Center for Biological Diversity, suhlemann[at]
  • Nick Fromherz, International Animal and Environmental Law Clinic, Lewis & Clark Law School, nfromherz[at]


  1. The Environmental Investigation Agency (EIA) investigates and campaigns against environmental crime and abuses. Our undercover investigations expose transnational wildlife crime, with a focus on elephants, pangolins and tigers, and forest crimes such as illegal logging and deforestation for cash crops such as palm oil; we work to safeguard global marine ecosystems by tackling plastic pollution, exposing illegal fishing and seeking an end to all whaling; and we address the threat of global warming by campaigning to curtail powerful refrigerant greenhouse gases and exposing related criminal trade.
  2. The Center for Biological Diversity is a national non-profit conservation organisation with more than 1.7 million members and online activists dedicated to the protection of endangered species and wild places.
  3. The International Animal and Environmental Law Clinic at Lewis & Clark Law School works with governments, non-governmental organisations and international institutions to develop, implement and enforce international law to tackle some of today’s most challenging global issues, including climate change, biodiversity conservation, oceans and fisheries, and trade and the environment.


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