China’s TCM Reform: Removing Pangolin Scales From the Pharmacopoeia

In June 2020, China’s National Medical Products Administration published the 2020 edition of the Pharmacopoeia of the People’s Republic of China. For the first time in the document’s history, pangolin scales — listed under the Chinese name chōn shājiă (窄岛申) — were absent. The delisting was widely reported as a historic breakthrough in global pangolin conservation. Understanding what it actually means, what it does not mean, and what remains unresolved requires a careful look at how traditional Chinese medicine is governed, how demand is generated, and how illegal markets respond to policy signals.

What the Pharmacopoeia Is and Why It Matters

The Pharmacopoeia of the People’s Republic of China is the official compendium of medicines approved for medical use in China. First issued in 1953 and revised roughly every five years, it defines the standards for drugs produced and prescribed in Chinese hospitals, clinics, and government-regulated pharmacies. Inclusion in the Pharmacopoeia is required for a substance to be legally manufactured as a TCM ingredient in China.

Pangolin scales had appeared in various editions since 1963. The 2015 edition listed chōn shājiă for use in treating conditions including blood stasis, amenorrhoea, and insufficient lactation. Hospital pharmacies and licensed TCM practitioners across China could legally prescribe and dispense scale-based medicines produced from a regulated stockpile maintained since commercial trade was banned in 2007.

The delisting from the 2020 Pharmacopoeia means that no new medicines containing pangolin scales can be approved for manufacturing in China from that point forward. The approximately 65 pharmaceutical products that had previously received approval based on Pharmacopoeia-compliant scales are now in a legal grey zone: those already approved may remain on the market while existing stockpiles last, but no new production runs using pangolin scales as an ingredient can receive regulatory sign-off.

The Policy Timeline

The 2020 Pharmacopoeia delisting did not emerge from nowhere. It was the culmination of a policy trajectory that had been building for years:

• 2007: China banned commercial trade in pangolins and pangolin products. However, medicinal use from a government-regulated stockpile remained permitted.
• 2017: CITES Appendix I listing for all eight pangolin species came into effect, extending the trade ban internationally. China voted in favour.
• 2020, February: Following the COVID-19 outbreak and widespread scientific discussion of pangolins as a possible intermediate host, China announced a temporary ban on the consumption of wild animals. Public pressure to address wildlife markets intensified.
• 2020, June: The 2020 Pharmacopoeia edition was published, without pangolin scales.
• 2020, June: China also upgraded domestic pangolin species protection to the highest tier under the Wildlife Protection Law, removing the loophole that had allowed “medicinal use” exceptions.

The COVID-19 context clearly influenced the timing and public salience of these reforms. Whether the scientific basis for the pangolin-COVID hypothesis has held up or not, the outbreak created political conditions in which action on wildlife markets was publicly demanded and institutionally feasible in ways that had not previously been the case.

What Changed After Delisting

Conservation organisations monitoring the Chinese market have documented several measurable changes following the 2020 reforms:

Reduced visibility in regulated markets. Wildlife monitoring organisations including TRAFFIC China and the Environmental Investigation Agency reported reduced open availability of pangolin scale products in registered pharmacies and regulated TCM clinics. Physical products from brands that had previously manufactured approved scale-containing medicines were less prominent in pharmacy surveys conducted in 2021 and 2022 compared to pre-2020 baselines.

Price volatility in illicit markets. Reports from underground market monitoring and trader interviews suggested significant short-term price increases in illicit pangolin scale markets following the 2020 announcements, consistent with supply disruption rather than demand collapse. High prices indicate that demand persists even as formal supply routes are constrained.

Shift to online channels. TRAFFIC’s monitoring of Chinese e-commerce platforms and messaging applications documented a migration of pangolin scale offerings from physically inspectable marketplaces to encrypted messaging channels, second-hand goods platforms, and cross-border commerce services. This digital displacement makes enforcement harder, not easier.

Substitution within TCM formulations. Several established TCM hospitals and research institutions developed and published clinical protocols for substituting pangolin scales with plant-based alternatives — including chúanshānjiān (a plantain lily extract) and specific combinations of húngliàng (safflower) and yùjīn (turmeric root) — for the blood-stasis and lactation indications where scales had previously been used. The medical evidence base for pangolin scales was already thin; practitioner uptake of substitutes appears to have been significant in the formal hospital system.

What Has Not Changed

The limits of the reform are as important as its achievements.

The stockpile loophole. China maintains a government stockpile of pangolin scales that was accumulated before commercial trade was banned in 2007. Products approved before the 2020 Pharmacopoeia revision can legally continue to use these stockpiled scales until the stockpile is exhausted or the products’ approvals lapse. The size of this stockpile has never been publicly audited, making it impossible to know how long existing approved products can remain in legal supply — or whether illegal scales are being laundered through stockpile claims.

Demand persists in non-clinical contexts. Pangolin scales are sought not only for their documented pharmaceutical applications but for broader “tonic” and status uses that operate outside the formal hospital system. In this market — which includes expensive health products, gifts, and informal practitioner prescriptions — regulatory changes to the Pharmacopoeia have limited direct reach. A product sold as a traditional health food or dietary supplement does not require Pharmacopoeia approval.

Vietnam, Hong Kong, and other markets. China’s domestic reforms do not affect demand in Vietnam, where traditional medicine use of pangolin products is substantial and the regulatory framework is different. Hong Kong’s market, historically a transit and retail hub for pangolin products, operates under its own jurisdiction. High-income mainland Chinese consumers can and do purchase products across these borders.

Enforcement gaps remain large. China’s wildlife enforcement capacity is unevenly distributed. The formal system — registered pharmacies, licensed hospitals, customs checkpoints at major ports — can be monitored and increasingly is. Informal markets in second and third-tier cities, rural areas, and online platforms are harder to police systematically. The pangolin trafficking networks that supplied Chinese markets before 2020 were not dismantled by a policy change; they adapted.

Long-Term Significance

Despite these caveats, the 2020 delisting represents a structurally important shift. Pharmacopoeia status is the formal basis for legitimacy in China’s regulated medical system. Products that cannot cite Pharmacopoeia approval cannot be prescribed in public hospitals or reimbursed under the national health insurance system. Over time, this removes the social and institutional scaffolding that made pangolin scale use a mainstream, respectable medical choice rather than a fringe practice.

Demand reduction in wildlife trade is a slow process measured in decades, not years. The 2020 reforms did not end pangolin consumption in China. They removed the most important source of official legitimacy for that consumption, reduced access through the dominant regulated channel, and created conditions for substitution to become standard practice in the hospital system. These are the preconditions for long-term demand reduction — necessary but not sufficient on their own.

The conservation significance of the reform also depends on what happens in parallel: strengthened seizure and prosecution, continued demand monitoring, and sustained public communication about pangolin conservation status. Policy change without accompanying enforcement and public engagement does not translate into reduced trafficking. With those complements, the 2020 Pharmacopoeia delisting stands as one of the most significant demand-side interventions in the history of pangolin conservation.

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