Pangolins and CITES: The History of International Legal Protection

Pangolins hold a grim distinction. They are widely regarded as the most heavily trafficked wild mammals on Earth, with an estimated one million individuals poached in the decade between 2004 and 2014 alone. In response to this crisis, the international community has turned to the most powerful legal instrument available for regulating wildlife trade: the Convention on International Trade in Endangered Species of Wild Fauna and Flora, better known as CITES. This article traces the history of pangolin protection under CITES, examines what the treaty can and cannot do, and asks whether international law is keeping pace with the reality on the ground.

What Is CITES and How Does It Work?

CITES is a multilateral treaty that entered into force in 1975. It currently has 184 Parties, making it one of the most widely adopted conservation agreements in the world. Its purpose is straightforward: to ensure that international trade in specimens of wild animals and plants does not threaten their survival in the wild. It achieves this through a system of permits and three tiers of protection known as Appendices.

Appendix I lists species threatened with extinction for which commercial international trade is prohibited. Trade is only permitted in exceptional circumstances, such as for scientific research, and requires both an export and an import permit. Appendix II lists species that are not yet threatened with extinction but could become so unless trade is closely controlled. International trade is allowed with an export permit and evidence that the trade is not detrimental to the species. Appendix III contains species that any individual country has asked other CITES Parties to help it regulate, requiring cooperation across borders.

Decisions to move species between Appendices are made at the Conference of the Parties (CoP), which typically convenes every two to three years. These decisions carry legal weight: each Party is required to adopt domestic legislation that implements the treaty's provisions.

Pangolins Under CITES: A Timeline

The relationship between pangolins and CITES stretches back to the earliest years of the treaty. Asian pangolin species were first included in Appendix II in 1975, the same year CITES entered into force. By 1995 all eight pangolin species, four Asian and four African, were listed on Appendix II. This listing permitted regulated international trade, but it also required exporting countries to demonstrate that such trade was not detrimental to wild populations.

By the late 1990s, it was clear that regulated trade was failing to protect Asian pangolins. Populations of the Chinese pangolin (Manis pentadactyla) and Sunda pangolin (Manis javanica) were declining sharply under intense commercial harvesting. At CoP11 in 2000, the Parties established zero export quotas for wild-caught Asian pangolins traded for commercial purposes. In practical terms this was a proxy trade ban: no country could legally export wild-caught Asian pangolin specimens for commercial sale.

The zero-quota mechanism, however, lacked teeth. Seizure data gathered by TRAFFIC, the wildlife trade monitoring network, showed that illegal trade in pangolins surged through the 2000s and into the 2010s. Traffickers exploited weak enforcement, porous borders, and the absence of equivalent protections for African species. As Asian pangolin populations collapsed, trafficking networks shifted their supply chains to Africa, sourcing scales and whole animals from the white-bellied pangolin (Phataginus tricuspis), black-bellied pangolin (Phataginus tetradactyla), giant pangolin (Smutsia gigantea), and Temminck's ground pangolin (Smutsia temminckii), the species most familiar to South Africans.

CoP17 in Johannesburg: A Landmark Moment

The turning point came in September 2016 at CoP17, held in Johannesburg, South Africa. Proposals to transfer all eight pangolin species from Appendix II to Appendix I were submitted, and the results were overwhelming. The vote for the four Asian species passed 114 to 1. The vote for the four African species was unanimous. It was one of the most decisive outcomes in CITES history.

The Appendix I listing, which took effect 90 days later in January 2017, banned all commercial international trade in pangolins. That the vote took place on African soil was symbolically significant. South Africa, as host nation, played a visible role in facilitating the discussions, and the decision sent a clear signal that Africa's own pangolin species would not be sacrificed to fill the supply gap left by the depletion of Asian populations.

"For the first time, all eight species of pangolin receive the highest level of international trade protection. This is a watershed moment for the world's most trafficked mammal." -- Wildlife Conservation Society, September 2016

Before CITES: A Legal Vacuum

It is worth recalling what the world looked like before CITES protections existed. Prior to 1975, there was no international legal framework restricting pangolin trade. Pangolin skins were commercially exported for leather goods, particularly from Southeast Asia. Pangolin meat was traded locally and regionally as a luxury food item. Pangolin scales were sold in bulk for use in traditional medicine. None of this was illegal at the international level. The absence of regulation meant that commercial exploitation proceeded unchecked, with no requirement for sustainability assessments or population monitoring.

Even after the initial Appendix II listing, the regulatory framework was permissive. Exporting countries were required to issue permits and conduct non-detriment findings, but many lacked the institutional capacity or political will to do so rigorously. The era of effectively unregulated trade continued in practice long after the legal framework was nominally in place.

Paper Protection Versus Reality

The Appendix I uplisting was a legal milestone, but conservationists are quick to point out the gap between law and enforcement. CITES is only as strong as the national legislation that implements it, and the capacity of individual countries to enforce that legislation varies enormously.

Not all 184 CITES Parties have enacted domestic laws that meet the treaty's minimum requirements. A country might be a Party to CITES and yet lack the penalties, the customs training, the forensic laboratory capacity, or the judicial understanding needed to prosecute pangolin trafficking effectively. In some range states, pangolin trafficking carries penalties so low that they fail to deter organised criminal networks whose profits can rival those of the narcotics trade.

South Africa offers a relatively strong example of national implementation. The country's National Environmental Management: Biodiversity Act (NEMBA) and associated Threatened or Protected Species (TOPS) regulations list Temminck's ground pangolin as a Vulnerable species, and illegal possession or trade carries significant criminal penalties. Yet even in South Africa, prosecutions remain difficult. Pangolins are recovered alive from traffickers with troubling regularity, and conviction rates do not always reflect the severity of the offence.

The Domestic Trade Loophole

One of the most persistent challenges is that CITES governs international trade, not domestic markets. Some range states continue to permit domestic trade in pangolin products, particularly for use in traditional medicine. This creates a significant enforcement problem. Where domestic sale is legal, illegally sourced pangolin products can be laundered into lawful supply chains. Stockpiles of confiscated scales, if not properly secured and destroyed, can re-enter markets and further blur the line between legal and illegal trade.

Recognising this gap, the Parties adopted a resolution at CoP19 in Panama City in 2022 urging all countries to close their domestic markets for commercial trade in pangolin specimens. Compliance, however, remains voluntary in practice. The resolution carries political and moral weight, but it does not override national sovereignty.

Ongoing CITES Work and the Role of Science

CITES has not treated the Appendix I listing as the end of the story. The Standing Committee, which meets between CoPs, has maintained pangolins as a standing agenda item. At its 78th meeting in Geneva in 2025, the Committee reviewed reports on national implementation and discussed the development of conversion parameters, standardised methods to determine how many individual pangolins are represented by a given quantity of seized scales. This technical work, led by the CITES Secretariat in collaboration with the IUCN SSC Pangolin Specialist Group, is essential for law enforcement and prosecution.

TRAFFIC continues to provide the seizure data and trade analysis that underpins CITES decision-making on pangolins. The IUCN SSC Pangolin Specialist Group, a global network of biologists, social scientists, veterinarians, legal experts, and criminal investigators, contributes population assessments, range-state analyses, and technical guidance. Their work feeds directly into the CITES process, informing the evidence base on which Parties make decisions.

At CoP20 in Samarkand, Uzbekistan, in late 2025, the Parties agreed on next steps for species most affected by poaching and illegal trade, including pangolins. However, efforts to formally identify the countries most responsible for driving illegal pangolin trade were deferred to the next Standing Committee meeting in 2026, illustrating the tension between scientific urgency and diplomatic process.

Looking Ahead

CITES provides the most important international legal framework for pangolin protection, but it is not a complete solution. The treaty can prohibit international commercial trade. It can require Parties to adopt domestic legislation. It can direct scientific bodies to gather data and recommend actions. What it cannot do, on its own, is dismantle the criminal networks that drive trafficking, change consumer demand, or fund the ranger patrols and habitat protection that pangolins need to survive.

For South Africa and other range states, the challenge is to translate the legal protection that CITES provides into tangible outcomes for pangolins in the wild. That requires investment in law enforcement, judicial training, cross-border intelligence sharing, and community engagement. The legal architecture exists. The question is whether the political will and the resources will follow.