Pangolin Trade Before CITES: A History of Legal Commerce

The pangolin trafficking crisis that dominates conservation headlines today did not begin in the shadows. For much of the twentieth century, the killing and selling of pangolins was legal, documented, and commercially significant. Hundreds of thousands of pangolin skins passed through regulated customs houses and trade statistics. The collapse of Asian pangolin populations was not the product of an illicit network operating beyond the reach of law — it was, in large part, the product of commerce operating within it. Understanding this history is essential to understanding why pangolins are in crisis today, and why the legal instruments that were supposed to protect them took so long to arrive.

Pangolins in the Pre-CITES Trade Era

The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) entered into force on 1 July 1975, after achieving the requisite ten ratifications. Before that date, and for several decades after, the international wildlife trade operated under minimal multilateral regulation. Individual countries maintained their own export and import rules, but there was no binding global framework requiring that commercially traded species be assessed for sustainability, and no mechanism for coordinating quotas across supplier and consumer nations.

In this environment, pangolins were traded extensively. Their skins were fashioned into leather goods — boots, bags, belts, wallets — marketed across Europe, North America, and East Asia. Their scales were exported for use in traditional Chinese medicine, where they had been listed as a therapeutic ingredient for over a millennium. Their meat was consumed as a luxury food in parts of China, Vietnam, and across sub-Saharan Africa. None of this required illegal networks. Hunters, traders, and exporters were operating within whatever rules applied in their jurisdictions — and for most of the twentieth century, those rules placed few effective limits on pangolin harvest.

Hong Kong: A Window on the Trade Volume

Hong Kong's position as a major entrepot for Asian wildlife trade means its import and export statistics provide one of the clearest historical windows on pangolin trade volumes. TRAFFIC, the wildlife trade monitoring network, compiled data from Hong Kong customs records showing that between 1958 and 1974 alone — the period immediately before CITES — Hong Kong legally imported over 80,000 pangolin skins. In peak years, imports exceeded 10,000 skins annually. The majority originated in Malaysia and Indonesia, with additional supplies coming from the Philippines and mainland China.

These figures almost certainly understate the total trade. Skins processed before export, unreported harvest, and trade through other major ports — Singapore, Taiwan, Japan — operated alongside Hong Kong's documented flows. The aggregate global harvest of pangolins for leather and scale products in the 1950s through 1970s was likely in the hundreds of thousands annually, though precise totals will never be recoverable from incomplete records.

The effect on Asian pangolin populations was severe. Chinese pangolin (Manis pentadactyla) populations, which ranged across southern China, Taiwan, and parts of Southeast Asia, collapsed during this period. Malayan pangolin (Manis javanica) populations in Peninsular Malaysia and Indonesia were substantially reduced. By the time CITES mechanisms began operating, the reservoir species that had supported the trade for centuries were already severely depleted.

CITES and the First Protections

When CITES took effect in 1975, pangolins were not among its initial listings. The convention's first Conference of the Parties (CoP1) in Bern in 1976 addressed hundreds of species, but pangolins did not receive significant attention at this stage. They were known to be heavily traded, but population data sufficient to support a listing argument was limited for most species, and the convention's scientific resources were stretched across a much larger taxonomy.

The first meaningful CITES protection came incrementally. Indian pangolin (Manis crassicaudata) and Chinese pangolin (Manis pentadactyla) were listed in Appendix II, allowing regulated trade, in 1975. Appendix II does not prohibit commercial trade; it requires that exports be accompanied by permits demonstrating the specimen was legally obtained and that export will not be detrimental to the survival of the species. In practice, through the 1980s and 1990s, these requirements were poorly enforced. Permit systems were undermined by forgery, corruption, and the difficulty of distinguishing pangolin products by species at the point of inspection.

Malayan pangolin and Sunda pangolin were added to Appendix II in subsequent CoP meetings. By 2000, all four Asian pangolin species held Appendix II status. At CoP11 in Gigiri, Kenya, in 2000, a zero annual export quota was recommended for Asian pangolin species removed from the wild and traded for primarily commercial purposes. This was a significant step — a zero quota effectively prohibited commercial international trade even under Appendix II — but implementation remained patchy, and domestic trade within range states continued legally under national laws that varied widely.

African Pangolins: Later to the Table

The four African pangolin species — Temminck's ground pangolin (Smutsia temminckii), giant ground pangolin (Smutsia gigantea), white-bellied tree pangolin (Phataginus tricuspis), and black-bellied pangolin (Phataginus tetradactyla) — received CITES Appendix II listing in 1994. Their trade had not historically been as large in scale as that of Asian species, partly because demand was more localised and partly because Africa had not been a primary supplier to the major Asian consumer markets until the 2000s.

In South Africa, the Temminck's ground pangolin (Smutsia temminckii) received statutory protection under national legislation, including the Nature Conservation Ordinances of the Transvaal, Cape, and Orange Free State. The species was listed as protected before the post-apartheid era's consolidated environmental legislation. However, enforcement capacity in rural areas was limited, and traditional use — primarily for traditional medicine and as a prestige food — continued in various forms.

The shift that changed the dynamic for African pangolins was the collapse of Asian supply chains. As Chinese pangolin and Malayan pangolin populations declined under sustained exploitation, trafficking networks began sourcing from Africa to meet continued demand in China and Vietnam. The transition accelerated sharply after 2010, and African range states found themselves facing a trafficking pressure they had not previously encountered at scale. The legal trade frameworks that had been sufficient when demand was primarily local proved entirely inadequate to the new international trafficking economy.

CoP17, Johannesburg 2016: Full Appendix I Protection

The culmination of the regulatory arc came at the 17th CITES Conference of the Parties, held in Johannesburg in September 2016 — the first CoP held on African soil in 28 years. Proposals to uplist all eight pangolin species from Appendix II to Appendix I were tabled by multiple parties, including the United States, the European Union, and several African range states including South Africa. Appendix I listing prohibits commercial international trade; trade for non-commercial purposes, such as scientific research, requires permits from both exporting and importing countries and is subject to strict scrutiny.

The debate at CoP17 was not without opposition. Several delegations, including representatives from some range states, expressed concern that Appendix I listing would criminalise what they characterised as sustainable domestic use, or argued that uplisting was premature given incomplete population data for some species. These arguments were ultimately unsuccessful. The uplisting of all eight species passed with strong majorities. The decision entered into force on 2 January 2017.

The CoP17 outcome represented the formal end of legal international commercial trade in pangolins. It did not end the illegal trade, which had long since displaced the legal market. By 2016, researchers at TRAFFIC estimated that over a million pangolins had been illegally traded in the preceding decade, making pangolins the most trafficked mammal on earth by volume. Appendix I status was the right legal foundation, but it was a tool for prosecution and interdiction, not a cure for the demand that drove the market.

China's Traditional Medicine List and the 2020 Moment

One of the most consequential developments in the legal history of pangolin trade protection came not through CITES but through Chinese domestic regulation. China's 2015 Pharmacopoeia — the official regulatory document governing approved medicinal ingredients — listed pangolin scales (chuan shan jia) as an approved ingredient for a range of traditional medicine formulations. This domestic listing created a legal channel for the use of existing stockpiles of scales and, critics argued, provided cover for laundering illegally sourced scales into the legal market.

In June 2020, following intense scrutiny generated partly by the COVID-19 pandemic and the public association of wildlife markets with zoonotic disease risk, the Chinese government removed pangolin scales from the National Pharmacopoeia's list of approved traditional medicine ingredients. Pangolins simultaneously received the highest level of protection under China's domestic wildlife protection law, upgraded from Category II to Category I. The 2020 reforms were widely described as the most significant domestic legal protection pangolins had ever received in China. Whether implementation has matched the regulatory change remains a subject of ongoing monitoring.

The Lesson of the Legal Trade Era

The history of legal pangolin commerce offers a particular lesson for conservation policy: legality is not the same as sustainability, and the absence of a prohibition is not evidence that a harvest level is safe. For much of the twentieth century, the pangolin trade was conducted entirely within the law. It was also, in aggregate, a catastrophe for pangolin populations across Asia. The regulatory response — incremental, delayed, and consistently outpaced by market demand — arrived too late to prevent the decimation of species like the Chinese pangolin, whose populations have not recovered despite decades of protection.

For African pangolin species, including the Temminck's ground pangolin of South Africa, the lesson is that protective frameworks must be enforced with a severity commensurate with the demand pressures they face. The legal architecture now exists: CITES Appendix I, national endangered species legislation, mandatory minimum sentences in South Africa for pangolin trafficking offences. The question is whether implementation keeps pace with the illegal market that has replaced the legal one.