Pangolin Scales in Traditional Chinese Medicine: What Science Actually Says

Pangolins are the world's most trafficked mammal, with an estimated 2.7 million poached annually in Africa alone. A significant driver of this crisis is demand for their scales in traditional Chinese medicine (TCM). Yet modern science has been unambiguous: pangolin scales are made of keratin — the same structural protein found in human fingernails, hair, and rhinoceros horn — and contain zero unique biochemical compounds with proven medicinal value. No clinical trial has ever validated the therapeutic claims that have driven these animals to the brink of extinction.

In March 2025, China took what appeared to be a decisive step by removing all pangolin-containing formulas from its national Pharmacopoeia. But as conservation analysts have since made clear, the gap between pharmacopoeia standards and enforceable law remains dangerously wide.

What Pangolin Scales Actually Are

Pangolin scales are composed entirely of keratin, a fibrous structural protein. This is the same material that forms human fingernails, hair, and the horns of rhinoceroses. Despite centuries of use in TCM, modern pharmacological studies have found no active compounds in pangolin scales that justify any medicinal claims. There is nothing in the biochemical profile of these scales that cannot be found in a human fingernail clipping.

TCM traditionally prescribed pangolin scales — known as chuan shan jia (or squama mantis in pharmaceutical nomenclature) — for promoting lactation, reducing swelling, improving blood circulation, and relieving arthritis. These uses were listed in TCM texts going back centuries, but not a single one has been validated by clinical trials conducted to modern scientific standards.

It is worth noting that even within the long history of TCM, the use of animal-derived ingredients was not universal. Sun Si Miao, a prominent 7th-century Tang Dynasty physician, notably excluded animal ingredients from his formulas — demonstrating that animal-free traditions in Chinese medicine predate the modern conservation movement by over a thousand years.

The 2025 Pharmacopoeia: A Landmark Removal

On 25 March 2025, China released the latest edition of the Pharmacopoeia of the People's Republic of China, effective from 1 October 2025. This edition removed all 13 remaining pangolin-containing formulas, completing a process that began with the 2020 edition, which had removed raw pangolin scales (squama mantis) as a standalone ingredient but left those 13 compound formulas intact. In total, 19 medicines were delisted in the 2025 edition.

The move was welcomed by conservation organisations worldwide. World Animal Protection issued a statement noting that the removal "indicates it no longer meets criteria for safety, efficacy or ethical acceptability." Christina Vallianos of WildAid stated: "I do think it sends a positive signal — it's a step in the right direction."

For pangolin advocates, the signal was clear: China's own pharmaceutical authorities were acknowledging that these products have no place in evidence-based medicine. Coming alongside China's June 2020 decision to upgrade all pangolin species to the highest level of domestic protection (Class I), the Pharmacopoeia revision appeared to close a significant chapter in the legalised exploitation of pangolins.

The Loopholes That Remain

Closer analysis by the Environmental Investigation Agency (EIA) and Mongabay, however, revealed critical gaps in enforcement. The central problem is structural: the Pharmacopoeia is a standard, not a law. It has no direct regulatory power over what treatments can be registered and marketed in China.

Under China's Medicinal Product Administration Law, Article 28, pharmaceutical substances can still be registered if they "comply with general medical quality standards." Crucially, standards from previous editions of the Pharmacopoeia remain applicable. This means manufacturers can continue producing formulas excluded from the 2025 edition by referencing older guidelines — a loophole that conservation groups have described as functionally undermining the removal.

The EIA was blunt in its assessment: "Just because pangolin formulae have been removed, it doesn't mean companies will stop producing them." The organisation noted that over 200 licensed manufacturers still held pangolin product licences, though this number has been declining since 2018. Separately, 47 Chinese pharmaceutical companies were documented advertising 57 products containing pangolin scales.

China's domestic market for pangolin scales remains open under an annual quota of one metric ton. No explicit species ban exists for pangolins in medicine — closing this gap would require China to "revise its laws or issue a notice to explicitly ban the use of a species," according to EIA analysts. Without such a ban, the Pharmacopoeia removal remains a significant but incomplete measure.

The Scale of the Trafficking Crisis

The urgency of closing these loopholes cannot be overstated. Pangolins are the most heavily trafficked mammals on earth. An estimated 2.7 million pangolins are poached annually in Africa alone, with a significant proportion of confiscated scales destined for traditional medicine markets in China and Vietnam.

All eight pangolin species are now listed on the IUCN Red List, ranging from Vulnerable to Critically Endangered. In 2016, the Convention on International Trade in Endangered Species (CITES) moved all pangolin species to Appendix I, banning international commercial trade entirely. Despite this, illegal trafficking networks continue to operate at industrial scale, driven by persistent demand.

The connection between TCM demand and population collapse is direct and well documented. As Asian pangolin populations have been depleted, trafficking networks have shifted their sourcing to Africa, creating a transcontinental supply chain that threatens species on both continents.

Demand Reduction and Plant-Based Alternatives

Alongside legal and regulatory reform, conservation organisations are investing heavily in demand-reduction campaigns. WildAid and partner NGOs run public awareness programmes in China and Vietnam aimed at reducing consumer demand for pangolin products. These campaigns frame the issue not only as a conservation crisis but as a matter of scientific literacy: the products simply do not work.

Within the TCM community itself, there are growing calls for change. In October 2022, the Coalition for Wildlife Protection in TCM brought together 15 TCM practitioners in San Francisco who formally endorsed plant-based alternatives to pangolin scales and other wildlife-derived ingredients. The TAWAP project (TCM Alternatives to Wild Animal Preparations) has been cataloguing herbal substitutes that can replace pangolin scales in traditional formulations without requiring any animal-derived material.

China's National Medical Products Administration has also announced efforts to develop official herbal alternatives, a move that could provide regulatory cover for manufacturers looking to reformulate their products. If plant-based substitutes are formally endorsed at the national level, the commercial incentive to continue using pangolin scales would diminish significantly.

Where We Stand

The removal of pangolin formulas from China's 2025 Pharmacopoeia is a genuine milestone. It represents an official acknowledgement by one of the world's largest pharmaceutical markets that pangolin-derived products fail the basic tests of safety and efficacy. Combined with the CITES Appendix I listing, China's Class I species protection, and growing demand-reduction efforts, the direction of travel is clear.

But direction is not the same as arrival. The legal loopholes identified by the EIA and other analysts mean that pangolin products can still be lawfully manufactured and sold in China. The annual quota for domestic pangolin scale use remains in effect. Over 200 manufacturers still hold relevant licences. Until Chinese law explicitly prohibits the use of pangolin parts in medicine — not just removes them from a pharmacopoeia standard — the world's most trafficked mammal remains in legal limbo.

The science has been settled for years: pangolin scales are keratin, nothing more. The policy is catching up, but the enforcement gap must be closed before we can claim genuine progress.

Frequently Asked Questions

Are pangolin scales medically effective?

No scientific evidence supports any medicinal benefit. Pangolin scales are keratin, the same protein as human fingernails. No clinical trials have demonstrated efficacy for any of the traditional claims, including promoting lactation, reducing swelling, or relieving arthritis.

Did China ban pangolin scales in medicine?

China removed all 13 pangolin-containing formulas from its 2025 Pharmacopoeia, effective October 2025. However, the Pharmacopoeia is a standard, not a law, and previous-edition standards still allow manufacturers to produce these products. An explicit legal ban on using pangolin parts in medicine has not yet been enacted.

What are the herbal alternatives to pangolin scales?

TCM practitioners have identified multiple plant-based substitutes. The TAWAP (TCM Alternatives to Wild Animal Preparations) project catalogues herbal alternatives, and China's National Medical Products Administration has announced efforts to develop official plant-based replacements. In 2022, 15 TCM practitioners in San Francisco formally endorsed these alternatives through the Coalition for Wildlife Protection in TCM.

How many pangolins are killed for traditional medicine?

An estimated 2.7 million pangolins are poached annually in Africa alone. A significant portion of confiscated pangolin scales are destined for traditional medicine markets in China and Vietnam. All eight pangolin species are now listed as Vulnerable to Critically Endangered on the IUCN Red List.