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In 2008, the "Catalogue of Prohibited Categories of Processing Trade" was introduced, adding 39 high-pollution and high-environmental-risk products. This year, the "Second Catalogue of Prohibited Commodities in Processing Trade for 2007" came into effect, drawing increased attention due to its inclusion of certain endangered species of animals and plants.
The Ministry of Commerce and the General Administration of Customs jointly issued Announcement No. 22 of 2008, which officially implemented the 2008 Prohibited Processing Trade Catalogue starting April 5. According to the Ministry’s website, the new catalogue is based on the 2008 national import and export tariff schedule, with technical revisions made to the previous list. Additionally, 39 new entries were added based on recommendations from relevant state agencies, focusing on high-pollution and high-risk items.
During an interview, a reporter noted that this update included 39 new prohibited items, some involving pharmaceutical intermediates. However, with a one-month grace period and the allowance for existing contracts to be fulfilled, the industry believes the impact is limited. Meanwhile, the 2007 Second Catalogue, which took effect this year, has drawn significant attention, particularly for including Chinese medicines containing endangered animal and plant ingredients for the first time.
The prohibition of processing trade items has long been a topic of debate. Starting in 2004, products like endangered animal skins were banned from processing trade exports. According to official explanations, the catalogue bans related products from being imported or exported through processing trade, but it does not restrict general trade. Therefore, companies can still engage in regular import and export activities.
However, the 2007 Second Catalogue now extends the ban to include traditional Chinese medicines, potentially affecting enterprises involved in bear bile and terpenoid products. Yu Mingde, Vice President of the China Pharmaceutical Enterprise Management Association, stated that while there are impacts, the export volume of endangered ingredient-containing medicines is currently very small and not widely traded in major markets.
He also emphasized that the conflict between traditional Chinese medicine and conservation efforts has always existed, and endangered species should indeed be protected. However, there is a need for better communication between national culture and international standards.
It is known that several well-known Chinese proprietary medicines contain endangered animal components, such as Pixianzhi, Angong Niuhuang Pills, and Yunnan Baiyao. These have previously caused controversy, with some countries seizing large quantities of suspected illegal products. However, with increased awareness and explanation, many international conservationists have come to understand the importance of balancing health and conservation.
Regarding plant-based extracts, the 2008 Catalogue largely followed the 2007 version, continuing the prohibition of oleoresins and oxygen-containing compounds from endangered plants. Domestic plant extract companies had hoped for more refined customs codes, but their expectations were not met. Most companies now focus on artificial cultivation rather than wild harvesting.
Liu Zhanglin from the Chinese Medicine and Health Products Chamber of Commerce noted that few companies engage in processing trade of endangered plant extracts, as most operate under artificial cultivation. He also mentioned that customs struggles to differentiate between wild and cultivated materials, leading to challenges in enforcement.
Zeng Jianguo from the Hunan Province Traditional Chinese Medicine Extract Engineering Research Center highlighted that the lack of refined customs codes indicates cautious policy-making. Although hopes for change were dashed, the continuation of last year’s policies limits the impact on the industry. He urged the government to consider the growing plant extract sector.
Artificial cultivation is seen as a viable solution. For example, ginkgo extracts can be processed if accompanied by artificial planting certification. The government is also investing in projects like the Guangxi Traditional Chinese Medicine Modernization Industry Special Project, aiming to establish breeding bases for endangered medicinal plants.
Yu Mingde concluded that if a species becomes endangered, it should be re-evaluated based on current conditions. Artificial cultivation and breeding could help reassess the status of certain species, a point that deserves greater attention from the traditional Chinese medicine industry.