All Eight Pangolin Species Uplisted to CITES Appendix I (2016) — A Decade Later, Trafficking Continues

Jurisdiction: International (CITES Parties) Law or Treaty: Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), Appendix I Last verified: 2026-05-23

Summary

At the 17th Conference of the Parties (CoP17) in Johannesburg in September–October 2016, all eight species of pangolin (the four Asian species — Manis crassicaudata, M. javanica, M. pentadactyla, M. culionensis — and the four African species — Phataginus tetradactyla, P. tricuspis, Smutsia gigantea, S. temminckii) were transferred from CITES Appendix II to Appendix I [CITES CoP17 2016]. Appendix I prohibits international commercial trade. The decision was widely characterised as the strongest possible CITES action available for the species and was supported by nearly all party countries with limited opposition.

A decade later, the trade has changed shape but not collapsed. UNODC's World Wildlife Crime Report 2024 documented continued large-scale seizures of pangolin scales and bodies during 2018–2022, with the global trade increasingly shifting from Asian to African pangolin species as Asian populations were depleted [UNODC 2024]. China's removal of pangolin scales from the Chinese Pharmacopoeia in 2020 was a meaningful demand-side intervention; full implementation in TCM hospitals continues [State Forestry Administration of China 2020].

This brief is a case study in what CITES Appendix I can and cannot do alone.

What CITES Appendix I did

The CoP17 uplisting:

  • Made any commercial international trade in pangolins (live, dead, scales, meat, or any derivative) a treaty violation
  • Required every party country to refuse Appendix I export permits except for non-commercial scientific purposes
  • Triggered domestic-law changes in many range states bringing national wildlife protection up to CITES Appendix I standards
  • Created the legal basis for cross-border enforcement coordination (Interpol, Europol, UNODC) targeting the trade

The proposal at CoP17 was supported by the African range states for African species and by the Asian range states for Asian species, with the United States, the European Union, the United Kingdom, and most African and Asian parties voting in favor. China — a major destination market — supported the African species uplistings and did not oppose the Asian species uplistings. The proposal carried by consensus on most species and by overwhelming majority on the rest [CITES CoP17 2016].

What happened next

Continued large-scale seizures. The UNODC World Wildlife Crime Report 2020 documented an estimated equivalent of approximately 195,000 pangolins seized in 2019 alone (in the form of bodies and scales). The 2024 report continued to document multi-tonne scale seizures into the early 2020s, though shipment volumes from East African ports increased while shipments from Southeast Asia decreased [UNODC 2020; UNODC 2024]. The geographic shift reflects depletion of Asian populations and the trade's response — not enforcement success.

The China Pharmacopoeia removal (June 2020). China's National Pharmacopoeia Commission removed pangolin scales from the 2020 edition of the Chinese Pharmacopoeia — the official reference text for traditional Chinese medicine ingredients — and uplisted Chinese pangolin to first-class national protection [State Forestry Administration of China 2020]. The change removed pangolin scales as a legally prescribable TCM ingredient at the national-formulary level. Implementation in hospitals and pharmacies has lagged the formulary change; legacy stockpiles, prescriptions by individual TCM practitioners, and underground markets continue at reduced scale.

Operation Thunder series. Annual cross-border enforcement operations coordinated by Interpol and the World Customs Organization have produced significant interdictions of pangolin trafficking. Operation Thunder 2020 reported the seizure of approximately 1,400 tonnes of illegally-traded wildlife and timber across the operation as a whole, with pangolin scales among the categorised products [INTERPOL 2020]. Subsequent annual operations have continued the pattern.

Domestic prosecution rates. A persistent enforcement gap: while couriers and low-level traffickers are regularly arrested, prosecutions of organisers and high-volume traffickers remain rare across most destination and transit countries.

Who is accountable

This brief names no individual defendants. The accountability actors are:

  • CITES Secretariat and Standing Committee. Responsible for monitoring party compliance, recommending trade suspensions for non-compliant parties, and convening enforcement working groups. The pangolin-specific work has been ongoing since CoP17.
  • CITES party governments — particularly major destination markets (mainland China, Vietnam) and transit countries (Nigeria, Cameroon, Hong Kong SAR). Each is responsible for domestic enforcement of the international commercial trade prohibition.
  • Range state wildlife agencies. Indonesian KLHK, Vietnamese CITES Management Authority, Chinese National Forestry and Grassland Administration, and equivalent African range state agencies (Nigeria, Cameroon, Gabon, etc.).
  • Interpol and the World Customs Organization. Coordinators of cross-border enforcement.
  • UNODC. Wildlife and forest-crime programme, publisher of the World Wildlife Crime Report series.

What worked

  • CITES Appendix I uplisting itself as a legal framework. Every subsequent enforcement action against the pangolin trade has been on the legal basis the uplisting created.
  • China's 2020 Pharmacopoeia removal as the single most consequential demand-side policy action. The TCM-formulary status of pangolin scales was the principal cultural and economic basis for the trade.
  • The IUCN SSC Pangolin Specialist Group — the scientific coordination body that has provided the technical basis for CITES decisions, IUCN Red List assessments (all eight species now Critically Endangered, Endangered, or Vulnerable), and enforcement targeting.
  • Save Vietnam's Wildlife (SVW) — the highest-volume Asian pangolin rehabilitation and reintroduction NGO. Documented release of hundreds of seized animals with post-release telemetry monitoring [SVW 2024].

What failed

  • Demand suppression in destination markets has been partial. Consumer surveys show younger urban Chinese and Vietnamese populations report lower willingness to consume pangolin products than older demographics; older and rural demand persists. WildAid and Education for Nature Vietnam consumer-attitude work has documented the shift but the trade volume has not collapsed proportionately [WildAid 2023; ENV ongoing].
  • Enforcement of high-volume traffickers. Most arrests are at the courier or low-level retail end; convictions of organised networks running multi-tonne shipments have been rare.
  • The geographic shift to African pangolins indicates that the trade is supply-elastic: when Asian populations were depleted, the trade found African source populations rather than diminishing demand commensurately. Without sustained demand-side suppression, range-state enforcement alone cannot stabilise the global population.
  • Captive-breeding alternatives have not emerged. Pangolins are stress-sensitive, diet-specialised, and prone to mortality in captivity. Multiple captive-breeding research programmes have failed to establish self-sustaining captive populations. Unlike many trafficked species where captive supply could partially substitute for wild capture, pangolins offer no commercially-relevant captive-breeding option.

What readers can do

  • Do not buy any pangolin product. This includes scale-based traditional-medicine preparations sold under names that obscure pangolin content. International commercial trade is prohibited under CITES Appendix I regardless of claimed provenance.
  • Support Save Vietnam's Wildlife. SVW is the highest-impact Asian pangolin rehabilitation NGO. Donations directly fund veterinary care for confiscated animals and post-release telemetry monitoring.
  • Support TRAFFIC and the Wildlife Justice Commission. TRAFFIC monitors the trade through its sub-regional offices and supplies intelligence to enforcement agencies. The Wildlife Justice Commission conducts long-term undercover investigations targeting organised wildlife-trafficking networks.
  • Engage on CITES enforcement. CITES is intergovernmental; civil-society pressure on individual parties to enforce Appendix I provisions matters. Public-comment processes during CITES Conference of the Parties cycles affect resolution adoption.
  • Support African pangolin range-state programmes. As the trade shifts to African source populations, in-country conservation in Nigeria, Cameroon, Gabon, the Democratic Republic of the Congo, and other African range states becomes proportionately more important. African Wildlife Foundation and Pangolin Crisis Fund are direct funding channels.
  • For TCM practitioners and TCM consumers: the Chinese Pharmacopoeia no longer lists pangolin scales. Substitute formulations using non-animal-sourced ingredients are documented in the contemporary TCM literature. Practitioners who continue to prescribe pangolin scales are not following current national pharmacopoeia.

References

  • CITES (2016). Conference of the Parties 17, Resolutions and Decisions — transfer of all pangolin species from Appendix II to Appendix I. Johannesburg, South Africa, September–October 2016. https://cites.org/eng/cop/17/
  • INTERPOL (2020). Operation Thunder 2020 — major wildlife and timber crime operation summary. https://www.interpol.int/
  • Save Vietnam's Wildlife (2024). Pangolin Rescue and Rehabilitation Programme — Annual Report. https://www.svw.vn/
  • State Forestry Administration of China / National Pharmacopoeia Commission (2020). Removal of pangolin scales from the Chinese Pharmacopoeia, 2020 edition. National Forestry and Grassland Administration, Beijing.
  • United Nations Office on Drugs and Crime (UNODC) (2020). World Wildlife Crime Report 2020: Trafficking in protected species. UNODC, Vienna.
  • United Nations Office on Drugs and Crime (UNODC) (2024). World Wildlife Crime Report 2024: Trafficking in protected species. UNODC, Vienna.
  • WildAid (2023). Reducing demand for pangolin products in China — consumer survey and campaign impact. https://wildaid.org/

NRWL Enforcement briefs are editorial summaries of public records. They are not legal advice. Court documents, agency reports, and IG reports cited inline are the authoritative sources; if a citation link breaks or you find a factual error, please report it on the Transparency page.

Every named defendant on this page is sourced to a filed court document. Allegations are described as alleged until adjudicated. Where facts are uncertain we mark them “verification pending” rather than guess.

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