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Publications archive - Biodiversity


Key departmental publications, e.g. annual reports, budget papers and program guidelines are available in our online archive.

Much of the material listed on these archived web pages has been superseded, or served a particular purpose at a particular time. It may contain references to activities or policies that have no current application. Many archived documents may link to web pages that have moved or no longer exist, or may refer to other documents that are no longer available.

Healthy people - healthy wildlife

Proceedings of the second Australian Symposium on traditional medicine and wildlife conservation
Melbourne Australia, March 1999

The Responsible Use of Traditional Chinese Medicine

Alan Bensoussan
Chinese Medicine Unit
Faculty of Health
University of Western Sydney Macarthur

The traditional Chinese materia medica includes preparations made from plant, animal and mineral products. Many of these preparations have been in use for centuries and have detailed indications for use in traditional Chinese medicine (TCM) practice. Some are made from parts of endangered species of animals or plants. The use of parts of endangered species such as rhinoceros horn, tiger bone and deer musk as medicinal preparations may have placed a significant strain on these species and contributed to the reduction of their numbers to critical levels (Callister and Blythewood 1995).

In Australia, the Wildlife Protection (Regulation of Exports and Imports) Act 1982 is the legislative basis for conservation-orientated controls on the export and import of wildlife and wildlife products. This Act fulfils Australia’s legislative requirement as a signatory to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Species under CITES control are classified under three appendices (see figure 1).

Figure 1: CITES Appendices

Appendix I

Includes species threatened with extinction that are, or may be, affected by trade. International commercial trade is prohibited.

Appendix II

Includes species that may become threatened if trade in them is not controlled. An export permit issued by the relevant government agency in the country of origin is required to trade internationally in Appendix II specimens.

Appendix III

Contains species subject to regulation within individual countries and for which the cooperation of other CITES parties is sought in order to control that trade.

The use of preparations claiming to contain endangered species in Australia has continued despite Australia becoming a signatory to the CITES (see figure 2). Nearly 43,000 units of TCM products claiming to contain bear, leopard, musk, rhinoceros and tiger were seized by the Australian government between July 1991 and March 1995. Of the 42,917 seized products 33,030 (78.3 %) listed musk; 22,006 (52.2 %) listed tiger; 1,379 (3.3 %) listed rhinoceros; 536 (1.3 %) listed leopard; and 257 (0.6 %) listed bear (Callister and Blythewood 1995).

TRAFFIC Oceania carried out a survey in Australia in February 1995 of 119 premises supplying TCM medicinal preparations. They found that 50 % of the shops examined were selling products containing musk and saiga antelope; 21.8 % leopard; 14.3 % tiger; 5.0 % bear and 2.5 % rhinoceros. All of these species are listed in the CITES Appendices I or II.

Figure 2: Principal animal species used in TCM which are threatened with extinction and therefore listed in CITES Appendix I (Modified from Callister and Blythewood 1995).

Common Name

Scientific Name

Sun Bear; Sloth Bear; Spectacled Bear; Asiatic Black Bear

Helarctos malayanus; Melursus ursinus; Tremarctos ornatus; Ursus thibetanus

Himalayan Brown Bear

Urus arctos isabellinus

Brown Bear

Ursus arctos (populations of Bhutan, China, Mexico and Mongolia)


Panthera pardus

Clouded Leopard

Neofelis nebulosa

Musk Deer

Moschus spp.(populations of Afghanistan, Bhutan, India, Myanmar, Nepal and Pakistan)


Rhinocerotidae spp.

Guadalupe Fur Seal; Monk Seal

Arctocephalus townsendi; Monachus spp.


Panthera tigris

TRAFFIC’s investigation of over-the-counter sales of Chinese medicines identified a problem particularly amongst prepared medicines rather than raw products. There was an inconsistency in the findings between the number of patent medicines labelled as containing endangered species and the availability of the same as raw ingredients. The only raw form of an endangered species found was antelope in two of the 119 Chinese herb stores surveyed (and this was not confirmed as saiga antelope). There were no other identifications of raw products from endangered species in Chinese herb stores. This inconsistency (with the volume of patent medicines identified as containing endangered species) may signal an important problem.

The TRAFFIC survey was unable to analyse prepared medicines to see if, in fact, the endangered species were actually contained in the medicines. Most TCM practitioners and retailers are aware that claims on labels can be rather extravagant. It is also widely known within the TCM profession that pork bone is used as a substitute for tiger bone, and buffalo horn for rhino horn. Furthermore, farmed deer supply some of the demand for musk. Synthetic musk is also produced.

Changing legislation and manufacturing practices in China may also have impacted on this problem of labelling. Two of the most commonly found items in the TRAFFIC survey were medical plasters that formerly listed tiger as an ingredient. Tiger has since been removed from the list of ingredients and product names of these plasters (post-1993 legislation in China). Bear has been removed from the ingredient list in the new stock of Fargelin pills for piles. Hence, it is difficult to determine whether the new products still contain the endangered species, or whether they ever have in the last few years. A label on one more recent product tries to convince the consumer that this product contains genuine tiger bone, such is the reputation for substitutions to occur. It is difficult to be certain of the actual level of use of endangered species in prepared Chinese medicines.

Having said that, there can be little doubt those products which list tiger bone as an ingredient, whether genuine or fake, perpetuate a demand for real tiger bone and products containing it. The only ethical solution is to ensure no endangered species are contained in the products, and to ensure labelling is accurate and not false. (For example, pork bone is identified as one of the active ingredients, and not tiger bone, if that is the case). Furthermore, even if only one in one hundred products labelled with endangered species actually contained them, this would probably be sufficient to drive the species to extinction (see Figure 3).

A significant resolution emanating from a CITES conference is that any product which lists a CITES-listed species as an ingredient on its packaging should be treated as containing that species.

 Figure 3

figure three

It then becomes the responsibility of the manufacturers and traders to ensure a product neither contains any endangered species, nor is labelled as containing them. Retailers, TCM practitioners and consumers in Australia also need to be aware that all such labelled products will be treated as containing the illegal ingredients. The issue of labelling is an important one for the TCM profession to address.

However, there is another issue which is potentially more difficult. At a recent conference in Hong Kong there was opportunity for practitioners and traders to express concerns related to the use of endangered species. It is worthwhile looking at some of these comments briefly (see
Box 1).

Some sentiments that I have heard expressed in Australia are also reflected in the comments of a TCM academic in Hong Kong:

The dilemma faced by TCM users, however, can only be better appreciated if we can step into their shoes and then make judgements if we ourselves or our beloved ones are suffering from ailments that modern medicine offers little or no help whereas products from these animals may offer relief.

It is important to table these views because herein may lie the resistance to comply with the law, and to continue to sacrifice a constantly diminishing resource. It defies all logic. Even if we adopt the crudest perspective of some human right to continuously exploit natural resources, in this case if the medicine is valuable and in diminishing supply, the resource needs protecting.

Box 1: Portrayal of concerns relating to the use of endangered species.

 Hong Kong TCM retailer:
'According to the CITES, the trade of tigers, etc. is prohibited and those TCM practitioners who use such medicines to treat and save peoples’ lives, pharmacies and traders of such medicinal resources are liable to punishment. Such international convention protects animals but harms human beings, makes animals more worthy than mankind, and degrades mankind as if they were lower than animals. It is questionable that whether such kind of rules worth existing.'

' …the rights of human beings of using such resources to maintain their health, treat their diseases and sustain their survival, are ignored. The people who formulate such kind of rules are indeed ignoring human rights.'

Hong Kong TCM practitioners:
On rhino horn: 'Reasonable application should therefore be allowed and it is inappropriate to ban the medicine entirely.' 'The normal traffic of species for medical use should be set strictly aside from profit-deriving business trade.

Singapore Chinese Doctors Association:
'TCM practitioners are working for the good of health care for all mankind. It is not fair to treat us like profiteers or put the law on us.'

A resource that is non-sustainable is not a resource. It is a stock of short supply with a shelf life of one generation maximum. And in this sense alone the profession needs to do the utmost within its capabilities to cease all use of endangered species and utilise alternative products, or farmed or cultivated species at least until such a time as the supply of the medicine is stable and occurs under humane conditions.

Viable alternatives to many endangered species used in TCM do exist and extensive work is being undertaken to identify further appropriate substitutes and we’ll hear some of these shortly. The TCM profession and the community should absolutely reject any use of endangered animal and plant species in Chinese medicines.

How do we encourage the TCM community to act appropriately with regards to wildlife protection? No program in Chinese herbal medicine in Australia systematically deals with these issues:

These principles should be formalised in undergraduate education and in postgraduate continuing education.

In summary, whilst TCM has used in the past, endangered animal and plant, it is a practice that has not been permitted for some time in China, Japan, Hong Kong, Taiwan and Australia. However, despite severe penalties in some countries, it still occurs.

Very little has been done in the past to educate the TCM community in Australia on the provisions of CITES, the conservation impact of the use of endangered species in TCM, and the availability of effective substitutes. Collaboration with and education of the TCM community will be a crucial component of any effort to curb the demand for endangered species medicines in Australia.

The majority of Australian TCM professionals would claim they no longer use endangered species and are in fact, positively opposed to it. They would support the formation of any appropriate legislation in this area. It appears some patent medicines may be labelled incorrectly as containing endangered species, when in fact the substance may be farmed or synthetically produced. The incorrect labelling of patent medicines as containing endangered species is a significant issue. It may require some time to re-educate and encourage the hand of Chinese exporters.


Callister, D. J. and T. Blythewood. 1995. Of Tiger Treatments and Rhino Remedies: Trade in endangered species medicines in Australia and New Zealand. Sydney: TRAFFIC Oceania, Sydney.