China Traditional Chinese Medicine Holdings Co. Limited

China Traditional Chinese Medicine Holdings Co. Limited manufactures and markets pharmaceutical products containing body parts from globally threatened species, including saiga antelope horn, leopard bone, and pangolin scales. The company’s core business model is predicated on ingredients linked to illegal wildlife trade and species extinction risk—a practice the Norwegian Government Pension Fund Global’s Council on Ethics cited as an “unacceptable risk of contributing to severe environmental damage” when it excluded the firm in September 2021. The company provides no public data on the volume of threatened species parts it uses, their origin, or its stockpile management, rendering its supply chain opaque and its impact unquantifiable.

The company operates within a Chinese regulatory framework that maintains exemptions for the medicinal use of pangolin scales, leopard bone, and other threatened wildlife, despite broader bans on wildlife consumption. This legal carve-out facilitates a persistent industrial demand that drives poaching and trafficking—as evidenced by large-scale seizures of pangolin scales destined for the traditional Chinese medicine industry. The Environmental Investigation Agency notes the industry’s vast consumer base presents a “significant threat to the survival of endangered species.”

China Traditional Chinese Medicine Holdings has disclosed no specific plans to reformulate its products or replace threatened species ingredients with sustainable alternatives. The absence of any public transition strategy, coupled with the lack of supply chain transparency, means the company’s operations continue to contribute directly to documented ecological harm and the erosion of global biodiversity.