Pills, Powders, Vials and Flakes: the Bear Bile Trade in Asia

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Suggested citation: Foley, K.E., Stengel, C.J. and Shepherd,
C.R. (2011). Pills, Powders, Vials and Flakes: the bear bile
trade in Asia. TRAFFIC Southeast Asia, Petaling Jaya,
Selangor, Malaysia.
ISBN 978-983-3393-33-6
Cover: Composite image created by Olivier S. Caillabet
Photos from top to bottom:
1) Bear cub observed on farm in Hanoi, Viet Nam
2) Vials of bear bile observed on farm in Viet Nam
3) Alleged bear gall bladder observed for sale in Singapore
4) Pills claimed to contain bear bile for sale in Malaysia
Photograph credits:
M. Silverberg/TRAFFIC Southeast Asia (1,2)
C. Yeong/TRAFFIC Southeast Asia (3,4)

Pills, Powders, Vials and
Flakes:
the bear bile trade in Asia
Kaitlyn-Elizabeth Foley
Carrie J. Stengel
Chris R. Shepherd
Asiatic Black Bear at China Bear Rescue Centre, Chengdu.
© Animals Asia

CONTENTS
Abbreviations and acronyms
Denition of terms
Acknowledgements
Executive summary
Introduction
Species
Asiatic Black Bear
Sun Bear
Brown Bear
Bear bile
Bear farms
Bear trade
Trade routes
CITES
Methods
Field surveys
Seizure and CITES trade data analysis
Cambodia
Mainland China
Hong Kong SAR
Macao SAR
Taiwan
Japan
Republic of Korea
Lao PDR
Malaysia
Myanmar
Singapore
Thailand
Viet Nam (chapter authored in partnership with ENV)
General discussion
Bear bile products
Bear gall bladder
Bear bile pills
Bear bile product origins
Domestic vs. cross-border origin
Cross-border-sourced products
Legalities of bear bile trade
Bear farming
Enforcement and seizure data
Conclusion
Recommendations
General recommendations
Country-specic recommendations
References
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Pills, Powders, Vials and Flakes: the bear bile trade in Asia

ABBREVIATIONS AND ACROYNMS
ACRES Animal Concerns Research and Education Society
ASEAN-WEN Association of Southeast Asian Nations’ Wildlife Enforcement Network
AVA Agri-Food and Veterinary Authority (Singapore)
cm3 cubic centimetres
CIA Central Intelligence Agency (of the US Government)
CITES Convention on International Trade of Endangered Species of Wild Fauna and Flora
CNY Chinese Yuan Renminbi
CoP meeting of the Conference of the Parties to CITES
CPM Chinese Proprietary Medicines; for the purposes of this report, synonymous with TM and TCM
DPR Korea Democratic People’s Republic of Korea (also known as North Korea)
ENV Education for Nature Vietnam
ETIS Elephant Trade Information System
FPD Forest Protection Department (Viet Nam)
g gramme
GKU Green Korea United
ICCWC International Consortium on Combating Wildlife Crime
IES International Endangered Species of Wild Fauna and Flora (Japan)
INTERPOL International Criminal Police Organization
IUCN International Union for Conservation of Nature
kg kilogramme
LCES Law for the Conservation of Endangered Species of Wild Fauna and Flora (Japan)
MARD Ministry of Agriculture and Rural Development (Viet Nam)
ml millilitre
MYR Malaysian Ringgit
TWD New Taiwan Dollar
SAR Special Administrative Region
SFA State Forestry Administration (China)
SGD Singapore Dollar
STOC Singapore TCM Organizations Committee
TCM Traditional Chinese Medicine; for the purposes of this report, synonymous with CPM and TM
THB Thai Baht
TM Traditional Medicine; for the purposes of this report, synonymous with CPM and TCM
UDCA Ursodeoxycholic acid
UNEP-WCMC United Nations Environmental Programme - World Conservation Monitoring Centre
USD United States Dollar
VNAT Viet Nam National Administration of Tourism
WAR Wildlife at Risk
WRRT Wildlife Rapid Rescue Team, Cambodia
WSPA World Society for the Protection of Animals
iiPills, Powders, Vials and Flakes: the bear bile trade in Asia

DEFINITION OF TERMS
Bear farm: Privately or publicly owned facility of any size, where wild-sourced and/or captive-bred bears are kept
for the primary purpose of extracting bile and/or the whole gall bladder. This term does not imply that
animals are maintained in appropriate conditions or that captive breeding occurs. Bear farms should
not be confused with zoological parks or other facilities where bears are kept in the absence of bear bile
or gall bladder collection being carried out. Bears on farms are sometimes referred to as ‘bile bears’ or
‘battery bears’.
Bile: Also known as gall; a uid produced by the liver and stored in the gall bladder that aids in the digestion
of lipids in the small intestine. In the context of this report ‘bile’ refers specically to the liquid extracted
from bear gall bladder.
Borneol: A compound derived from Borneo Camphor Dryobalanops aromatica teak trees, sometimes used in TM.
Cinnabaris: A naturally occurring mercury compound, also known as red mercuric sulphide sometimes used in TM.
Consumer: For the purposes of this report: countries/territories were considered consumers when a signicant
amount of bear bile products were readily available in the country/territory.
Cross-border: For the purposes of this report: a term used in reference to trade that moves across international and
territory boundary lines (e.g. Russia to China or China to Hong Kong SAR) and does not include in-
country/territory borders (e.g. provincial boundaries).
Flakes: For the purposes of this report; small pieces of dried bile or dried gall bladder, sometimes also described
as crystals or chips. Flakes, crystals and chips were all considered ‘akes’.
Gall bladder: A small organ, present in most vertebrates that stores bile produced in the liver. In the context of this
report ‘gall bladder’ refers specically to bear gall bladder sold by the gramme, piece or whole form.
Musk: A substance obtained from the musk gland of male musk deer Moschus spp. The main chemical
component, muscone, is a commonly used ingredient in TM products. All musk deer are listed as
CITES Appendix I or II.
Ointment: For the purposes of this report: a salve containing bear bile, typically used for the treatment of sores or
haemorrhoids.
Pills: For the purposes of this report: capsules or compound pills containing bear bile and/or bear gall bladder.
Powder: For the purposes of this report: dried bear gall bladder pieces or bear bile which has been ground into
powder and sold in either pure form or compounded with other products.
Producer: For the purposes of this report: countries/territories are dened as producers when raw materials for
the manufacturer of bear bile products come from these areas and/or these areas manufacture bear bile
products often seen in other countries/territories.
Stalactitum: Also know as a stalactite, a rock formation containing high levels of calcium carbonate and other
minerals sometimes used in TM.
Succinum: A substance derived from tree sap, also known as amber sometimes used in TM.
TM outlets: For the purposes of this report, areas where bear bile products were sold including TM shops and open
markets.
iii Pills, Powders, Vials and Flakes: the bear bile trade in Asia

ACKNOWLEDGEMENTS
The authors would like to especially thank Animals Asia Foundation, Maria Norbury Foundation, Stephen and Wendie
Ryter, and the Hauser Bear Foundation for making this research and report possible.
A special thanks to Education for Nature Vietnam, who agreed to partner with TRAFFIC Southeast Asia on the Viet Nam
section of this report.
Thanks go as well to the following specic people and organizations who contributed time and energy to help make this
report a success: Jill Robinson, Juanita Tom, Toby Zhang and Tuan Bendixsen of Animals Asia Foundation; Doug Hendrie
of Education for Nature Vietnam; Christopher Servheen; Chris Gee of World Society for the Protection of Animals; Matt
Hunt of Free the Bears Fund; Louis Ng of ACRES; Lye Fong Keng of AVA; Siew Te Wong of the Bornean Sun Bear
Conservation Centre; Lesley Perlman of Wildlife Alliance (Cambodia); Gabriella Fredriksson; Kim Miyoung of Green
Korea United; Kim Yooree; Gina Moon of Moonbears.org; Eric Busch; Wildlife At Risk; and Nirmal Ghosh.
Thanks also to our dedicated consultants who made the research component of this project possible: Mark Silverberg,
Adam Oswell, Charlene Yeong Yen-feng and Gail Jun of Korean Animal Welfare Association.
Many thanks to TRAFFIC colleagues who contributed their time including Noorainie Awang Anak, Nurul Bariyah Binti
Babu, Claire Beastall, Olivier Caillabet, James Compton, Julie Gray, Akiko Ishihara, Elizabeth John, Kahoru Kanari,
Kanitha Krishnasamy, Sean Lam, Xu Ling, William Schaedla and Joyce Wu.
Portions of the production of this report were made possible by contributions from the Rufford Foundation.
Maps used in this report were designed by Carrie J. Stengel; with the exception of the map in Figure 23, designed by
Olivier Caillabet.
ivPills, Powders, Vials and Flakes: the bear bile trade in Asia

EXECUTIVE SUMMARY
The trade of bear gall bladders and bear bile is a serious threat to the conservation of Asian bear species (Phillips and
Wilson, 2002). Although the use of bear bile is legal within some Asian countries, cross-border trade of bear bile products
is prohibited by the Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES) and
yet still occurs throughout the region. Furthermore, the commercial production of bear bile from bear farming has turned
bile from purely a traditional medicinal (TM) ingredient to a commodity with bile now being found in non-TM products
like cough drops, shampoo and soft drinks.
In order to assess the current trade of bear bile medicines in Asia, surveys were conducted in TM outlets in the countries
and territories of Cambodia, mainland China, Hong Kong Special Administrative Region (SAR), Japan, Republic of
Korea, Lao People’s Democratic Republic (PDR), Macao SAR, Malaysia, Myanmar, Singapore, Taiwan, Thailand and
Viet Nam. Bear farms were also surveyed in Lao PDR, Myanmar and Viet Nam and information about farms gathered
from various sources for mainland China, Japan and the Republic of Korea. Although during this research products from
DPR Korea and Russia were observed, these countries were not surveyed.
TM shops in the 13 countries/territories surveyed sold bear bile products, with the exception of those in Macao SAR.
Products were most frequently observed in mainland China, Hong Kong SAR, Malaysia, Myanmar and Viet Nam, where
they were seen at over 50% of the total TM shops surveyed. Products were observed at over 30% of surveyed TM shops
in Japan, the Republic of Korea, Taiwan and Thailand. Products were seen at less than 30% of surveyed TM shops in
Cambodia, Lao PDR and Singapore.
All of the countries/territories surveyed were observed to have a signicant amount (22% to 100%) of bear bile products
originating in other countries/territories for sale. Mainland China was the most commonly reported place of origin for bear
bile products across the region. In addition to this overall observation, there were notable market-specic observations for
Myanmar, Hong Kong SAR and the Republic of Korea among others. In Myanmar, cross-border-sourced gall bladders
were reported to be entirely from Lao PDR. In Hong Kong SAR, 100% of pills (where origin could be determined) were
reported to have originated in Japan. In the Republic of Korea, 60% of bear bile products were reported to have been
produced from wild bear populations in Russia; in Russia hunting and trade of Brown Bears is legal.
The products most frequently observed were gall bladders (by the gramme and in whole form) and pills. The prices for
these products ranged dramatically depending on the country/territory surveyed. Prices for whole gall bladders were as
low as USD51.11 (Myanmar) and as high as USD2000 (Hong Kong SAR). For gall bladder by the gramme, the least
expensive was USD0.11 per gramme (Thailand) and the highest was USD109.70 per gramme (Japan). Pill prices ranged
from as low as USD0.38 per pill (Malaysia) to USD3.83 per pill (Thailand).
Four farms were visited in Lao PDR, housing a total of 98 Asiatic Black Bears and four Sun Bears. No captive breeding
was reported at these facilities and all of the farms were foreign owned. Two farms were visited in Myanmar, housing a
total of 52 Asiatic Black Bears and three Sun Bears; all of which were reported to be wild caught from mainland China,
Lao PDR and Myanmar. In Viet Nam, a total of 34 farms were visited housing a total of 677+ bears (671 Asiatic Black
Bears, 6 Sun Bears). TRAFFIC surveys found that farm size in Viet Nam varied dramatically, housing from two to 60
individuals. Only four farms stated they had captive breeding programs. In Japan, a total of four bear parks were visited.
Most parks stated that bears were incinerated upon death and only one of the four sold bear products however they were
said to contain derivatives from wild bears, not the bears at the park.
The results from TRAFFIC’s recent surveys indicate that the presence of bear farms in a country is clearly correlated
with a country being both a producer and a consumer of bear bile products with the exception of the Republic of Korea,
where it is only correlated with being a consumer. This is because recent surveys in the Republic of Korea did not observe
a large amount of domestically sourced products (7%) or any products from the Republic of Korea in other countries/
territories. Overall it would appear that bear farms in Asia do not full any kind of conservation role as pressures on wild
vPills, Powders, Vials and Flakes: the bear bile trade in Asia

populations and a steady demand for bear bile persists throughout the region.
The scale of the bear bile trade in Asia is large, with several countries playing dual roles as producers and consumers.
This research suggests mainland China, Japan, Malaysia, Myanmar and Viet Nam are producers of bear bile products in
Asia. Cambodia, Lao PDR and Myanmar are also considered source-countries of wild bears for the trade, although the
extent of this wild-sourcing is unknown. In addition Lao PDR and Myanmar may be emerging markets for bear farms,
especially as pressures increase in China and Viet Nam to end bear farming. Nine of the 13 countries/territories can be
considered consumers to differing degrees: mainland China, Hong Kong SAR, Taiwan, Japan, Republic of Korea, Lao
PDR, Malaysia, Thailand and Viet Nam.
The majority of the trade in bear bile is illegal, violating national laws in most countries/territories and legislation
concerning imports and exports in all of them. An analysis of the origin of bear bile products found during the course of
this survey makes it clear that import and export regulations are commonly outed. CITES is clearly being ignored and
national regulations are largely not enforced as raw bile, manufactured bile products and live bears are being commonly
traded across country/territory borders.
Combating the illegal trade of bear bile products in Asia is essential for the conservation of wild bear populations. Even
with strong national legislation in place, many factors such as corruption, poor legislation and ineffective enforcement
often allow illegal wildlife trade to occur. Enforcement efforts to combat the illegal trade in bear bile products in Asia is
of paramount importance to ensure that trade dynamics do not threaten the survival of bears in the region. To evaluate
enforcement efforts and trade trends, TRAFFIC analysed bear bile related seizures. Information on a total of 506 bear
bile product related seizures from 2000 to 2010 were obtained from various sources including the United Nations
Environmental Programme World Conservation Monitoring Centre (UNEP-WCMC) CITES trade database. From these
collected data, a minimum of 7044 g of bile and 10 100 unspecied bear bile products have reportedly been seized since
2000. Approximately 409 of 506 seizures had a stated origin, purported to be China in 98% of cases. It should be noted
these data are likely an under-representation of total seizure-activity during this time period. Seizures are sometimes not
reported and a portion of illegal international trade often goes undetected.
The overall results of this study indicate there is a substantial amount of bear bile trade in Asia, much of which is illegal.
In order to combat the illegal trade of bear bile products in Asia and support the conservation of wild bear populations,
TRAFFIC recommends the following:
• TM outlets selling illegal bear parts and derivatives need to be penalized or closed down and illegal products
conscated. Individuals caught collecting, selling, buying transporting or keeping illegal bear parts and
derivatives, in violation of national laws or CITES, must be prosecuted. Penalties should be severe enough
to serve as a deterrent to individuals in the future.
• Better enforcement could appropriately be undertaken not only by CITES Authorities, police and Customs
authorities who are already empowered by national government to initiate such efforts, but also by
collaborative inter-governmental efforts, including through the Association of Southeast Asian Nations
Wildlife Enforcement Network (ASEAN-WEN) and the partner members of the International Consortium
on Combating Wildlife Crime (ICCWC – which links the CITES Secretariat, INTERPOL, the United
Nations Ofce on Drugs and Crime, the World Customs Organization and the World Bank).
• Illegal bear farms should be closed down permanently by relevant authorities in each country. Facilities
where bears cannot be immediately removed should be closely monitored by a combination of government,
international and civil society specialists to ensure harvesting of bile does not continue, new bears are not
acquired and bear farms are not a source of illegal trade. Violations should be punished to the full extent
of the law.
• Legal bear farms should be regularly monitored by designated authorities who monitor the wildlife trade to
viPills, Powders, Vials and Flakes: the bear bile trade in Asia

ensure they are adhering to regulations. Where violations occur; bear farm owners should be punished to
the full extent of the law.
• The CITES Secretariat/Standing Committee and/or individual Parties to CITES should take steps to ensure
that countries abide by the text of the Convention in regards to the international commercial trade in bears,
their parts and derivatives. Findings of this report should be raised by TRAFFIC and the IUCN SSC Bear
Specialist Group at the next meeting of the Conference of the Parties (CoP 16, Bangkok, Thailand, 2013).
• Campaigns by local and international civil society actors in collaboration with relevant government
agencies to tackle illegal consumption of bear bile products should be carried out in all consumer countries.
Campaigns should also focus on raising awareness amongst enforcement agencies so as to increase
motivation and capacity to tackle the illegal trade in bears, their parts and derivatives. Campaigns should
also be carried out in bear range States to raise the prole of bears and the need to protect them. Local
communities should be encouraged not only to protect bears but also to work with enforcement agencies to
take action against bear poachers and traders.
• All countries experiencing illegal wildlife trade should ensure anonymous wildlife crime hotlines are in
place and known to the public. The public should be encouraged to report all instances of illegal hunting
and trade of bears and bear products.
• In the interest of national accountability, TRAFFIC suggests that all cases pertaining to bears be tracked and
reported internationally via a centralized database. Such reporting of seizures, arrests and prosecutions is
done for elephants via the Elephant Trade Information System (ETIS) and moves are afoot to monitor Tiger
cases in a similar fashion. A system to manage and maintain a central database for bear-related seizures
in order to monitor trends and analyse bear trade should take into account the lessons learned from similar
databases established for other species. Information generated from this database should be provided in a
timely manner to relevant enforcement agencies.
Country-specic recommendations
• Current domestic legislation in China should be amended to up-list the Asiatic Black Bear from Category
2 to Category 1, as the species is considered Vulnerable with a globally declining population trend (IUCN,
2011).
• In mainland China, close all unlicensed bear farms as well as those farms which have licences but do not
adhere to current regulations. In addition, farm owners who contravene CITES regulations by illegally
exporting bile should have their bear farm licences revoked and be prosecuted to the fullest extent of the
law.
• As stated in Ishihara (2005), it is recommended that Japanese legislation be amended to include Japanese
domestic bears and bear gall bladders under the Law for the Conservation of Endangered Species of Wild
Fauna and Flora.
• The Republic of Korea should end the practice of bear farming in order to remove any confusion on the
legality of products in the country and to eliminate threats to wild bears.
• In Lao PDR and Myanmar, steps need to be taken to assist both countries to achieve Category 1 CITES
implementing legislation status. In absence of Category 1 status, punitive measures should be taken to
mitigate illegal trade in and from these countries.
• In Lao PDR, the trade of parts and derivatives from second generation captive-bred bears is permitted under
the Wildlife and Aquatic Law (2007) with proper approval. However as bears are protected in the country,
vii Pills, Powders, Vials and Flakes: the bear bile trade in Asia

obtaining parent stock from the wild is illegal. As it seems to be highly unlikely that bears are being bred
on farms and in the absence of monitoring systems to accurately determine whether the animals derive
from wild or captive sources; farms should be closed down to avoid abuse of this loophole. In addition,
legislation should be amended to close these loopholes and to more fully protect wildlife.
• In Malaysia, authorities should investigate shops and manufacturers selling and producing both real and
purported bear bile medicines and prosecute them accordingly.
• In Myanmar nes for violation of the Protection of Wild Life and Wild Plants and Conservation of Natural
Areas Law (1994) should be increased to deter poaching and trade.
• In Myanmar, the Asiatic Black Bear should be up-listed to Totally Protected on the list of Wildlife Protected
from the Forest Department.
• Research on the role Russia plays in the bear bile trade should be conducted as the results from these recent
surveys indicate that Russia is an important source of bear gall bladders in China, Republic of Korea and
Viet Nam and the proportion of illegal trade is unknown.
• In Viet Nam, authorities should enforce national legislation; bear farms should be closed down in Viet Nam
to prevent violations of national legislation and CITES commitments as there is evidence that these farms
illegally extract and sell bear bile to local and foreign consumers.
• Legislation in Viet Nam should be amended and claried: 1) to cover the import, export and transit of
species which are CITES-listed but of domestic or unclear origin as these are not included under the current
law, 2) to cover bear cubs born in captivity under the Regulation of Bear Management Decision 95/2008/
QD-BNN (2008), and 3) to clearly dene what constitutes the ‘possession’ or ‘keeping’ of bears.
viiiPills, Powders, Vials and Flakes: the bear bile trade in Asia

INTRODUCTION
Across South-east and East Asia there is a signicant and largely illegal trade in Asian bear species for the live animal
trade, meat trade and Traditional Medicine (TM) trade. Bear gall bladder and bile are valuable and sought-after TM
ingredients widely available in many countries. The TM trade encourages illegal poaching of bear populations and is
therefore a signicant threat to the survival of wild bears in Asia (Kemf et al., 1999; Williamson, 2007). The numerous
illegal aspects of the trade uncovered by this survey show a blatant disregard for national and international laws.
TRAFFIC aims to describe current trade dynamics by identifying key consumer and producer countries, primary source
countries, the ow of products between countries and the illegalities of bear bile trade. This is done with the purpose to
better understand Asia’s bear bile trade so as to make recommendations for stakeholders from governments to NGOs, in
the hope that illegal trade can be mitigated and Asian bears can be effectively protected.
Species
Bears Ursidae are a widespread family comprising eight species inhabiting a variety of ecosystems across four continents:
Asia, Europe, North America and South America. Of the eight species, four are endemic to Asia: the Asiatic Black Bear
Ursus thibetanus, Sun Bear Helarctos malayanus, Sloth Bear Melursus ursinus and Giant Panda Ailuopoda melanoleuca
(Table. 1). Two others occur in Asia but are not endemic, the Brown Bear Ursus arctos and the Polar Bear Ursus
maritimus, however the Polar Bear is only found in the Arctic region of Siberia. Three bears are specically targeted for
the bear bile trade (Table 1).
Table 1
Primary bear species found in bear bile trade in Southeast Asia
Species
Asiatic Black Bear
Ursus thibetanus
Sun Bear
Helarctos malayanus
Brown Bear
Ursus arctos
IUCN Vulnerable Vulnerable Least Concern
CITES Appendix I Appendix I Appendix I and II
Sources: IUCN, CITES Photos: C. Beastall/TRAFFIC Southeast Asia, G. Fredriksson, H. Jungius/WWF-Canon
1 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Asiatic Black Bear
The Asiatic Black Bear, sometimes referred to as the Moon Bear, is a medium-sized species rst described by Cuvier in
1823. These bears can be most easily identied by the ears which appear disproportionately large in comparison to the
rest of the head. They have a distinct v-shaped chest patch, which is cream/lemon in colour and often have a cream/lemon
colour on the chin.
The species has a patchy distribution across 18 countries and overlaps the distribution of Sun Bears in South-east Asia
as far south as Thailand (Figure 1) (Garshelis, 2002). Asiatic Black Bears have been classied as Vulnerable with a
decreasing population trend by the International Union for Conservation of Nature (IUCN) Red List since 1990. Although
no rigorous population assessments have been carried out, worst-case gures suggest there could be as few as 25 000
Asiatic Black Bears left in the wild. More optimistic estimates place populations at under 100 000 (MacGregor, 2010).
In 2003 China gave an ofcial government country estimate of about 28 000 however this has not been substantiated by
further scientic research (Garshelis and Steinmetz, 2008).
Figure 1
Estimated distribution of the Asiatic Black Bear
The type and extent of threats to the Asiatic Black Bear vary across its range. Habitat loss and degradation affect bears
in parts of their range where annual rates of forest loss are high. However, the major threat to the species in China and
South-east Asia is the commercial trade in live bears and their parts. The demand for bear products has increased over the
past several years and is very likely to be unsustainable, causing populations to decline (Kemf et al., 1999; Garshelis and
Steinmetz, 2005; Garshelis and Steinmetz, 2008). Asiatic Black Bears are nationally protected in many range countries as
well as internationally protected by the Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES) which has listed the species in Appendix I since 1979. The IUCN Red List has identied the most benecial
conservation action for Asiatic Black Bears to be a substantially reduced level of commercial demand for bear products
(Garshelis and Steinmetz, 2008).
Source: IUCN
Source: IUCN
2Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Sun Bear
The Sun Bear, also known as the Malayan Sun Bear or Honey Bear, is the smallest member of the bear family. First
described by Rafes in 1821, Sun Bears are currently split into two subspecies: the Bornean Sun Bear H. m. euryspilus
and the Sumatran Sun Bear H. m. malayanus (Meijaard, 2004). The species has a distinctive appearance with short dark
sleek fur, long curved claws and a bright u-shaped orange blaze across its chest.
The Sun Bear is native to 11 Asian countries and is regionally extinct in Singapore (Figure 2) (Fredriksson et al., 2008).
The IUCN classies the Sun Bear as Vulnerable with a decreasing population trend. It is suspected that Sun Bear
populations have declined by more than 30% over the past 30 years, due to massive deforestation and uncontrolled
exploitation for trade. Commercial poaching is a signicant threat despite the fact that killing bears is illegal in all range
countries (Kemf et al., 1999; Fuller et al. 2004; Meijaard et al. 2005; Tumbelaka and Fredriksson 2006; Wong 2006;
Shepherd and Shepherd, 2010).
Figure 2
Estimated distribution of the Sun Bear
Conservation action varies by country however no range States have established specic priorities for Sun Bears. Reducing
the trade in bear parts has been highlighted by the IUCN Red List as a highly benecial measure for the survival of species
populations (Fredriksson et al., 2008). Sun Bears have been listed in Appendix I of CITES since 1979 and international
commercial trade in them or their parts and derivatives is therefore illegal.
Source: IUCN
3 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Brown Bear
Described by Linnaeus in 1758, the Brown Bear is the largest member of the bear family and can vary signicantly in size
and colour across its broad distribution. The species is found in at least 45 countries around the world (Figure 3); however
the natural distribution was larger in the past. Brown Bears are possibly extinct in Bhutan, and are considered extinct in
the wild in 15 other range States (Garshelis, 2002; McLellan et al., 2008). While some populations of Brown Bears are
well known, the dynamics of others remain poorly understood.
Figure 3
Estimated distribution of Brown Bears
The Brown Bear is considered to be of Least Concern by the IUCN Red List with a stable population trend; however
this assessment is heavily inuenced by healthy North American and European populations. Summing various estimates
results in a rough estimate of a total world population of 200 000 plus bears (Servheen et al., 1999; Swenson et al.,
2000). This number can be misleading as in Asia little is known about Brown Bear density or habitat connectivity apart
from the fact that populations are thought to be sparse and fragmented (Garshelis, 2002; McLellan et al., 2008). Several
small populations in Asia are threatened due to low numbers and frequent contact with humans. Bears living near human
settlements are sometimes killed inadvertently or poached for their parts. The removal of even a few bears from small
populations can adversely affect population growth (Wakkinen and Kasworm, 2004; McLellan et al., 2008).
Current conservation action varies between regions and range states. Many populations are legally protected by national
laws, but enforcement efforts and effectiveness varies depending on the country. Brown Bears from Bhutan, China,
Mexico and Mongolia are listed in CITES Appendix I, thus prohibiting international commercial trade, but all other
populations are listed in CITES Appendix II which allows controlled international trade under a permit system.
Source: IUCN
4Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Bear bile
Bile is a liquid substance produced by the liver and aids in the digestion
of lipids in the small intestine in many vertebrate species including
humans. It is composed of over 97% water with small amounts of bile
salts, cholesterol, lecithin, electrolytes and fatty acids (Busch, 2008).
The acids are formed from cholesterol and include primarily colic
acid, chenodeoxycholic acid and ursodeoxycholic acid (UDCA) in low
concentrations. UDCA is found in several mammals however it is most
concentrated in bear bile, specically in Polar Bears, Brown Bears and
Black Bears where UDCA makes up to 15% to 39% of bile compared
to 5% in humans (Hagey et al. 1993). UDCA appears to be the only
therapeutic component of bile and no other acids have been shown to
have benecial effects for humans. Pharmaceutical grade UDCA is
produced from cows and other species, not including bears, often as a
by-product of slaughter. It was introduced into modern medicine in the
early 20th century and is currently used in gastric bypass surgery and to
treat liver diseases (Maas, 2000; Busch, 2008). Several pharmaceutical
companies produce synthetic UDCA and it is currently manufactured under several trade names including: Actigall,
Deursil, Ursosan, Ursofalk, Urso and UrsoForte (Roberts and Perry, 2000).
China, Japan and the Republic of Korea are known to consume over half the world’s annual production/supply of
pharmaceutical UDCA (Mills et al., 1995; Togawa and Sakamoto, 2002). However despite the availability of this
low-cost, concentrated UDCA product, bear bile from farmed and wild bears is still widely available in Asia. Due to
their synthetic origins, pharmaceutical products like Actigall are considered an unacceptable substitute by many TM
practitioners (Macartney, 2006).
Bear bile use in TM is historically documented however it is difcult to quantify how important or widely available it has
been in the past. The rst published record of the medical use of bear bile is in the Materia Medica, from the Tang Dynasty
in 659 AD (Feng et al., 2009). Bear bile is traditionally used to treat sore throats, sores, haemorrhoids, sprains, bruising,
muscle ailments, epilepsy and to ‘clear’ the liver (Busch, 2008; Vu, 2010). It is sold in various forms including: whole
gall bladders, raw bile, pills, powder, akes and ointment. There are over 54 varieties of herbal substitutes for bile listed
in Chinese pharmacopeia, however a demand for bear bile remains and bears are farmed to meet this demand (Still, 2003;
WSPA, 2005). With the introduction of commercialized bear farming and a resultant surplus production of bile, many
non-essential and non-traditional TM products are increasingly being produced and bile can now be found in everyday
commodities including wine, tea, and shampoo (Richards and Wang, 2006).
There are several health issues associated with farmed bears
which potentially affect bile potency. Farmed bears often have an
inamed and thickened gall bladder, recurrent abdominal
infections and a high rate of liver cancer (Busch, 2008). In
addition, unsanitary conditions and methods employed during
extraction and processing can result in contamination of bile
products with pus, debris, skin and impurities as well as toxic
materials (Cochrane, 2003; Loefer et al., 2007; Busch, 2008;
Loefer et al., 2009). Perhaps it is due in part to these concerns
that products using wild-sourced bile are often thought of as
superior medicines to farmed products.
Bear bile packaging tray
© M. Silverberg/TRAFFIC Southeast Asia
Bear bile from a farm in Viet Nam
© M. Silverberg/TRAFFIC Southeast Asia
5 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

In addition to removing the intact gall bladder from a bear, there
are four methods used to extract bile from living animals (Maas,
2000; Loefer et al., 2007; Feng et al., 2009; Loefer et al., 2009):
1. The catheter-free stulae method was developed in
China; a permanent incision in the abdomen and gall
bladder is made which allows the farmer to puncture
the same location to extract bile.
2. The metal catheter method uses a permanently
implanted metal tube to access bile.
3. The full-jacket method uses a permanent catheter
tube to extract bile which is collected in a plastic bag
located in a metal box worn by the bear.
4. The ultrasound method uses an ultrasound machine to locate the gall bladder, then the bear is punctured
and bile removed.
Bear farms
In the past, bear bile was taken from intact gall bladders
collected from bears killed in the wild. This method
failed to provide a steady bile supply to practitioners
of TM, making bear bile medicines very expensive.
In the late 1970s, a ‘technology’ was developed in the
Democratic People’s Republic of Korea (DPR Korea)
for obtaining bile from live bears, and hence ‘bear
farming’ began (Li, 2004). By 1984, bear farming
in China had been sanctioned by the government as
a conservation measure to preserve bears in the wild
(Wang et al., 1994). By 1989 over 8000 Asiatic Black
Bears and Brown Bears were being commercially
farmed for bile in China (Mills and Servheen, 1991),
within six years that number had increased to 10 000
(Mills et al., 1995). Currently the majority of farmed
bears are Asiatic Black Bears. As of April 2010, 20 provinces in China have outlawed bear farms; however an estimated
97 farms housing 7000 to 10 000 bears remain in operation (Animals Asia, 2010; MacGregor, 2010). It should be noted
the term ‘bear farm’ is used broadly in this report to include facilities that have wild-sourced and/or captive bred bears, but
does not imply that captive breeding commonly occurs in these facilities. Bear farms are currently legal in the Republic of
Korea and certain provinces in mainland China (Loeffer et al., 2009); they commonly occur in Viet Nam and to a smaller
extent in Lao People’s Democratic Republic (PDR) and Myanmar. In Asia, a minimum of 12 000 bears are currently
estimated to be housed in both illegal and legal bear farms (WSPA, 2010).
The establishment and existence of bear farms has not been proven to alleviate pressures on wild populations. The
average productive life span of a farmed bear is only ve years (Mills et al., 1995; Peppin et al., 2008). As captive bears
become less productive, they are replaced and there have been numerous accounts of farms using wild bears to replenish
their aging stock. Some studies indicate that bear faming and bear trade have reduced populations of Asiatic Black Bears.
A study by Feng et al. 2009, suggested that poaching in Sichuan province caused wild bear populations to decline despite
bear farms being abundant in this part of China. In a 2000 report by the World Society for the Protection of Animals
(WSPA), nearly all of 44 farms surveyed admitted to harvesting from the wild in order to ‘top-up’ stocks. In 2006, a
Bear bile packaging in a farm in Ha Noi, Viet Nam
© M. Silverberg/TRAFFIC Southeast Asia
Bear bile farm in Viet Nam
© M. Silverberg/TRAFFIC Southeast Asia
6Pills, Powders, Vials and Flakes: the bear bile trade in Asia

bear farmer in Viet Nam told Animals Asia that farms paid rural villagers to trap 12 wild bear cubs per year in order to
supplement farm stocks (Robinson et al., 2007). In Viet Nam, forests are becoming devoid of bears due to illegal hunting
and habitat loss causing hundreds of bears to be internationally trafcked from neighbouring countries (Nguyen, 2007).
Research has shown bears are regularly sourced from countries such as Cambodia and Lao PDR, where cubs destined for
bear farms in Viet Nam can be sold for around USD100 (Nguyen, 2007; Burbach, 2009; MacGregor, 2010).
As previous research suggests, bears are regularly sourced from the wild to re-stock bear farms and for their bile, as it is
often preferred to that of farmed bears. The surplus of farm-produced bile has led to the use of bear bile in more products,
thereby potentially generating more consumers and increasing demand. Farming has resulted in the perception that bears
and bear products are a readily available and acceptable commodity (Richards and Wang, 2006; Loefer et al., 2009).
Bear trade
The trade in bears and bear products is a major threat to the survival of wild bear populations in Asia (Phillips and Wilson,
2002). Live bears and their parts and derivatives are openly sold in TM outlets, TM shops, privately through dealers,
from bear farms and through a variety of other sources. The open and often international trade highlights the fact that
enforcement efforts to control trade have so far been inadequate (Shepherd, 2007). Although precise population numbers
for Asian bears are unknown, it is likely that the massive scale of commercial trade is directly responsible for population
declines (Williamson, 2007; Fredriksson et al., 2008; Garshelis and Steinmetz, 2008).
Bear parts and derivatives are heavily traded. These include the paws,
skin, claws, canine teeth, skulls and most prized of all: the gall bladder
and bile. In just a 12 day period, researchers in Myanmar found bear
parts representing a minimum of 215 bears being openly traded in
border markets near China and Thailand (Shepherd and Nijman,
2008). Bear bile is a heavily traded and often costly derivative with
consumers often willing to pay high prices for bile sourced from wild
bears (Kang and Phipps 2003).
Of the Asian bears, Asiatic Black Bears are the most heavily traded
and are relied upon predominantly to produce farmed bile, especially
in mainland China and Viet Nam (Huang and Li, 2007; Shepherd and
Nijman, 2008). Sun Bears are less present in farming operations but are commonly poached from the wild in Cambodia,
Lao PDR, Malaysia, Myanmar, Thailand and Viet Nam (Shepherd and Nijman, 2008; Fredriksson et al., 2008). Brown
Bears are not commonly farmed, but they are frequently seen in mainland Chinese bear farms. Brown Bear parts have
also been found in the Chinese trade (Jill Robinson, Animals Asia, in litt. to TRAFFIC Southeast Asia, April 2011) which
may be due to the fact that Brown Bears are legally hunted in Russia.
Trade routes
Consumer demand for bear bile products has fuelled the growth of complex cross-border trade networks in Asia. Although
bear farming may be legal in some places in China and the Republic of Korea, the trafcking of products from these farms
across borders is completely illegal under CITES regulations.
Surveys of border markets have demonstrated there is a frequent and large scale illegal trade in bear products. In 2006
TRAFFIC surveyed three border markets, Tachilek and Three Pagoda Pass on the Myanmar-Thailand border and Mong
La on the Myanmar-China border. Parts representing a minimum of 143 bears were found openly for sale in these
markets, with buyers moving items across borders with little to no problem (Shepherd, 2007). Past investigations by
TRAFFIC found bile for sale at the Sichuan and Shanghai international airports (Mills et al., 1995).
Bear bile from farms in mainland China primarily and to a lesser extent in Lao PDR, Myanmar and Viet Nam are suspected
to supply the black market trade. Several studies have found products in one country labelled as originating in a foreign
Bear claws for sale in Myanmar
© C. Shepherd/TRAFFIC Southeast Asia
7 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

country, in obvious violation of CITES. Findings in a study by Ng and Tan (2006) found that bear bile products for sale
in Singapore were often sourced from China but also from Russia, Thailand, India, DPR Korea, Malaysia and Indonesia.
Live bears used to supplement farm stock are also traded internationally as well as domestically. Farms in mainland
China and Viet Nam have been accused of purchasing bears from poachers operating in Myanmar, Cambodia and Lao
PDR (Watkins and Hsieh, 2000; Corlett, 2007; Robinson et al., 2007). A trade route through Ruili in Yunnan Province,
on the China-Myanmar border has been identied as a hub where bears from Myanmar and Laos are smuggled to Chinese
farms (Robinson et al., 2007).
CITES
CITES Parties are required to adhere to the Convention to curtail illegal international
trade and to monitor any legal trade of bears, their parts and derivatives. In
addition to international regulations, most countries have established adequate
national legislation to protect bears (Shepherd, 2007). In spite of these legislative
efforts, illegal hunting and trade continues to occur throughout Asia.
CITES Parties are required to be able to implement the Convention through
their own national legislation. Each Party’s legislation is assessed and has been
assigned a category under the CITES National Legislation Project (Table 2).
Categories are based on a Party’s ability to effectively implement CITES and are
dened as:
Category 1: Legislation which meets all the requirements for
implementing CITES.
Category 2: Legislation which meets some, but not all, of the
requirements for implementing CITES.
Category 3: Legislation which does not meet any of the requirements
for implementing CITES.
Resolution Conference 10.8 on the ‘Conservation of and trade in bears’ was
passed at the 10th meeting of the Conference of the Parties to CITES (CoP 10) in
1997. This states that ‘the continued illegal trade in parts and derivatives of bear
species undermines the effectiveness of the Convention. Furthermore, poaching
may cause declines of wild bears that could lead to the extirpation of certain populations or even species’. Parties are
urged to ‘take immediate action in order to demonstrably reduce the illegal trade in bear parts and derivatives’ (CITES
Res. Conf 10.8, CoP10).
In 2000, at the 11th meeting of the Conference of the Parties to CITES (CoP 11) Decision 11.43 was made to address the
trade in bears. Decision 11.43 states that Parties are required to report to the Secretariat any actions taken to implement
Resolution Conf. 10.8 (or any revisions) including (a) national legislation in place to control the trade in bear parts/
derivatives and (b) enforcement efforts and penalties for violating laws pertaining to bear parts/derivatives.
During the 12th meeting of the Conference of the Parties (CoP 12) in 2002, two decisions were made relating to the trade
of bears and bear products. Decision 12.27 states Parties that had failed to report to the Secretariat in 2001 (as required
in Decision 11.43) and that were listed as Parties who were believed to be large consumer and producer States for bear
parts and derivatives. These included the following South-east Asian countries: Cambodia, Republic of Korea, Malaysia,
Myanmar, Philippines, Singapore, Thailand and Viet Nam. Decision 12.28 established that the Standing Committee
would address the international trade in bear parts and derivatives at its 50th meeting (2004) with specic focus on
enforcement and legislative problems in regards to stopping illegal trade.
Country/Territory Category
Cambodia 1
China 1
Hong Kong SAR* 1
Japan 1
Lao PDR 3
Macao SAR 2
Malaysia 2
Myanmar 3
Republic of Korea 1
Singapore 1
Thailand 1
Viet Nam 1
Table 2
CITES National Legislation
Project categories
Source: CITES SC59 Doc.11 (2010)
*Hong Kong SAR and Macao SAR,
included as ‘Dependent Territories’ of
China by the CITES National Legislation
Project, have separate legislative
instruments to implement CITES.
8Pills, Powders, Vials and Flakes: the bear bile trade in Asia

At the 2004 meeting, the Standing Committee identied that the major problem for many Parties was distinguishing the
gall bladders of bears from those of other animals. The Secretariat addressed this issue by advising the use of forensic
analysis and further stated that such analysis could also differentiate between wild-caught and captive-bred bear parts/
derivatives. The Secretariat also stated that due to the lack of intelligence information from the Parties, it was difcult
for the Secretariat to provide proper counsel on effectively combating the illegal trade of bear parts/derivatives (SC50
Doc. 17).
In 2007, Resolution Conf. 10.8 was revised at the 14th meeting of the Conference of the Parties (CoP 14). This revision
urged Parties to increase CITES enforcement and establish or improve national legislation to control the import and
export of bear parts and derivatives.
Currently all of the study countries/territories in Asia have domestic legislation protecting wild bears with a few exceptions:
1. Myanmar lists Asiatic Black Bears as Protected, but they can be hunted with a permit, the Sun Bear is
Totally Protected.
2. In Japan bear hunting of Asiatic Black Bears and Brown Bears is permitted in designated areas, during
specic hunting seasons with a licence.
9 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

METHODS
TRAFFIC conducted research on the bear bile trade in Asia between June 2010 and April 2011. In order to thoroughly
assess current trade dynamics, a variety of methods were used, including eld surveys of bear farms and TM shops, an
analysis of the CITES trade data held by the United Nations Environmental Programme World Conservation Monitoring
Centre (UNEP-WCMC), seizure data analysis and comprehensive legislative reviews. All monetary values in this report
are presented in United States Dollars (USD), based on conversion rates from OANDA Forex Trading and Currency
Exchange Rates Service online in February 2011 (http://www.oanda.com).
Field surveys
Surveys of TM shops were conducted from August 2010 to February 2011 in the countries and territories of Cambodia,
mainland China, Hong Kong SAR, Japan, Republic of Korea, Lao PDR, Macao SAR, Malaysia, Myanmar, Singapore,
Taiwan, Thailand and Viet Nam. Bear farms and parks (Japan) were surveyed from September 2010 to February 2011
in Lao PDR, Myanmar, Japan and Viet Nam. Information from TM establishments and bear farms was gathered using
standardized survey forms. Major cities in each focus area were chosen, based on the localities of farms and high density
areas of TM shops (Table 3). Russia was not included in these surveys, however bear gall bladders reportedly sourced
from Russia were observed.
Table 3
Areas surveyed
Country/Territory Locations
Cambodia Bavet, Phnom Penh, Sre Khlong, Takeo, Ti Prammuoy
mainland China Guangzhou, Shanghai, Harbin, Chengdu, Beijing, Anguo
Hong Kong SAR Hong Kong SAR
Japan Osaka, Tokyo
Republic of Korea Seoul, Sungnam, Daegu
Lao PDR Boten, Lak Xao, Luang Namtha, Luang Prabang, Pakse, Thakhek, Vientiane
Macao SAR Macao SAR
Malaysia Ipoh, Kota Bharu, Kota Kinabalu, Kuala Lumpur, Kuching, Melaka, Miri, Penang, Sibu
Myanmar Kentung, Mandalay, Mong La, Mong Sat, Phangshan, Sop Lwe, Tachilek
Singapore Singapore
Taiwan Taipei, Kaohsiung, Taichung
Thailand Bangkok, Chiang Mai, Hat Yai, Kanchanaburi, Nakhon Sawan, Nong Khai
Viet Nam Moc Bai, Cu Chi, Dien Chau, My Tho, Ha Noi, Ha Long, Ho Chi Minh City, Quynh Luu,
Vinh
10Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Farm surveys were not conducted in mainland China and the Republic of Korea because it is prohibitively difcult for
researchers to access bear farms in both countries. Additionally in the Republic of Korea, the spread of foot-and-mouth
disease during the time of research made it impossible to survey farms. Therefore, information on farmed bears and
farming operations for these countries was obtained from other sources (Mills et al., 1995; Mills and Servheen, 1991;
Wang et al., 1994; Frances, 2009; Animals Asia, 2010; MacGregor, 2010; Sudworth, 2010; WSPA, 2010; Ministry of
Environment, Republic of Korea, 2011). Information obtained on bear farms was compiled into tables highlighting the
geographic locations of farms, the presence or absence of captive breeding, death rates, origin and sources of bears, prices
of bile, and marketplace destinations.
TM outlet surveys were conducted by researchers in local or appropriate language for the country/territory being surveyed
or in the company of a translator. No effort was made to determine between real and fake products. It should be noted,
however, that some products purported to be from bears were likely fake as it is very difcult to verify product authenticity
in the eld. In the context of this study CITES denitions were followed, therefore products claiming to contain bear
bile or gall bladder were considered such. Survey data from TM shops were compiled and the products observed were
categorized as gall bladder, bile, pills, powder, akes, ointment and other. Data on display, origin, price, manufacturer,
customer demand and customer preferences as well as anecdotal information were recorded whenever possible. The data
were analysed to show the number of shops selling each product, percentage that were openly displayed, percentage of
comparative geographic origin, price range and average price. Data were compared across the countries at the level of a
single unit (gramme, pill, and millilitre).
Seizures and CITES trade data analysis
Seizure data of conscated bear gall and bile products from 2000 to 2010 were compiled and analysed. This information
came from various sources. Information from the UNEP-WCMC CITES trade database from 2000 to 2009 only was
analysed, since data for 2010 to 2011 was not yet available. This database compiles all records of import export and re-
export of listed species as reported to the CITES Secretariat by the Parties and was used to look at data for the trade in the
three bear species (Asiatic Black Bear, Sun Bear and Brown Bear) and the 13 countries/territories covered in this report.
Seizure records were requested and received from several sources, specically: local and international news, HM Revenue
and Customs (United Kingdom), the UNEP-WCMC CITES trade database, TRAFFIC bulletins and reports, ACRES,
ENV, Wildlife Alliance, Agri-food and Veterinary Authority (AVA), Taichung Customs Ofcial website, the Forest
Bureau as well as Bureau of Foreign Trade, the designated points of contact for CITES in Taiwan, and the Agriculture,
Fisheries and Conservation Department Hong Kong SAR (Hong Kong SAR CITES Management Authority). A number
of other agencies/organizations were contacted, but either did not have data or did not respond to data request inquiries.
When available, data collection included: country where the seizure took place, date of seizure, seized items, origin, route,
enforcement agency, prosecution/sentencing and references. It was not possible to estimate the minimum and maximum
number of bears represented by the seizure data, since it was only possible to determine the number of bears when seizure
data referred to whole gall bladders.
It should be noted that seizure data are often incomplete and inconsistent. For example Customs, police and other
authorities may have made seizures and not reported them. Also, many shipments pass through check-points undetected.
Therefore, the seizure data collected for this report represent only a proportion of the total trade in live bear, bear parts
and derivatives. Although the reported trade is not representative of the total trade, it is possible to gain insight into trade
dynamics by using seizure data in conjunction with survey data from TM shops and farm surveys.
11 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

CAMBODIA
Cambodia is bordered by the Gulf of Thailand, Lao PDR, Thailand and Viet Nam (Figure 4). The total land area of 181
035 km2 is dominated by at plains with mountain ranges in the north and south west. The largest city and centre of
political and industrial activity is Phnom Penh, the nation’s capital. The total population of Cambodia is over 14.7 million
people, 31% of whom live below the poverty line (CIA, 2011).
Figure 4
Cambodia in relation to other areas of the study region
Cambodia became a Party to CITES in 1997. The CITES National Legislation Project has assessed Cambodia’s national
legislation as Category I, meaning that it is considered adequate to effectively implement CITES regulations. The Ministry
of Agriculture, Forestry and Fisheries serves as the CITES Management Authority and the Deputy Director General of the
Forestry Administration serves as the Scientic Authority.
There are two species of bears in Cambodia: the Asiatic Black Bear and Sun Bear. There is no ofcial information on the
distribution or population size of either species in Cambodia, though trade is considered a serious threat (Nea and Nong,
2006). Bears are hunted and traded in Cambodia for their parts, which are used widely for food and medicine (Suon,
1999). There are no known bear farms in Cambodia.
National legislation
Under the Law on Forestry of Cambodia, it is prohibited to possess, process, transport, import and engage in trade of
listed species or their parts and derivatives (‘specimens’). Article 48 of Cambodia’s Law on Forestry (2003), states that
‘all kinds of wildlife species in the Kingdom of Cambodia are state property and the component of forest resources’.
Violation of this law can result in nes of up to ve years imprisonment. The Asiatic Black Bear is listed as ‘endangered’
and the Sun Bear is listed as ‘rare’ on Cambodia’s Protected Species List (2007).
12Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Results
In October 2010, 17 TM shops were surveyed in Cambodia for bear bile products. Of these; four were found to be sell-
ing bear derivatives in gall bladder, raw bile and ake forms (Figure 4, Table 4). A total of ve gall bladders were seen
in two of the four shops. Raw bile sold for USD7 per 5g vial, averaging USD1.40 per gramme and manufactured by
Songgao (Chinese company). Flakes were priced slightly higher at USD12.50 per 5g vial and averaging USD2.50 per
gramme and were manufactured by Yicheng (Chinese company).
Table 4
Bear bile products observed in TM shops in Cambodia
Discussion
Current research suggests bear bile products are
available on a small but persistent scale in Cambodia.
Since none of the bear products observed were openly
displayed, it is reasonable to assume that traders are
aware that the trade in these is illegal. The presence of
products from China in TM shops suggests that these
have been imported into Cambodia in contravention of
CITES.
Both shops selling Cambodian-sourced gall bladders
stated they had a steady customer demand for the
product. One shop owner, who has been selling bear gall
bladder for over 10 years, said customers preferred wild
gall bladder. Gall bladders at this shop were relatively
inexpensive at USD50 per whole gall bladder. This
contrasted dramatically with the second shop surveyed
where the product cost USD1200. The reported price difference could be due to the size of the gall bladders for sale, the
source of the gall bladders or the fact that the Cambodian survey was conducted by a foreigner.
Previous research suggests there is a high monetary incentive to trade in wild bear gall bladder. In a survey of Cambodian
hunters in 2008, hunters received between USD150 to USD250 for a gall bladder, which were then sold on by traders for
USD500 to USD700 (Dutton, 2011).
As no bear farms are known to exist in Cambodia, products reported to be of Cambodian origin, such as the ve gall
bladders observed in TM shops, are likely sourced from wild bears. Wild bears from Cambodia are also used to replenish
captive bear stocks on farms in neighbouring countries such as China and Viet Nam (Robinson et al., 2007). Due to the
reported customer preference for wild gall bladder and a high economic incentive to hunt wild bears in Cambodia it is
reasonable to suggest that wild populations may be threatened by the bear bile trade.
Available
Product
# Shops
Selling
Product
Open Display
% of Shops Product Origin Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 2 0% Cambodia whole 50.00-1200.00 625.00/whole
Raw bile 1 0% China vial 7.00 1.40/g
Flakes 1 0% China vial 12.50 2.50/g
Yicheng Medicine from China observed at TM shop in Phnom
Penh
© M. Silverberg/TRAFFIC Southeast Asia
13 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

In 2001, a government enforcement team for wildlife trade known
as the Wildlife Rapid Rescue Team (WRRT) was established with
technical and nancial support from Wildlife Alliance. This has
greatly reduced both cross-border and internal trade of wildlife in
Cambodia (Shelton, 2008). The WRRT conscated a total of 77
live Sun Bears and 31 live Asiatic Black Bears from 2001 to 2010
(WRRT seizure data). Estimated averages of 10-15 bears are seized
each year; however this is thought to represent only a small portion
of those actually traded and numbers do not appear to be decreasing
(Shelton, 2008).
Overall, Cambodia would appear to have a comparatively small role
in the bear bile trade as products were not widely available and it
does not appear to be a major source country. However this small-
scale, persistent illegal trade in bear bile products is a concern,
especially as Cambodia may be a source country of wild bears for
bear farms in neighbouring countries.
Bear bile from China observed from in downtown
Phnom Penh
© M. Silverberg/TRAFFIC Southeast Asia
14Pills, Powders, Vials and Flakes: the bear bile trade in Asia

MAINLAND CHINA
The People’s Republic of China is the third largest country in the world with a total area of over 9.5 million km2 and
over 1.3 billion inhabitants, 2.8% of which live below the poverty line (CIA, 2011). The diverse geography of this
country includes plains, deserts and vast mountain ranges (Figure 5). In 1981, China became a Party to CITES and has
Category I legislation as assessed by the CITES National Legislation Project. The Endangered Species Import and Export
Management ofce of the State Forestry Administration (SFA) serves as the Management Authority and the Endangered
Species Scientic Commission of the Institute of Zoology, Chinese Academy of Science serves as the Scientic Authority
for CITES.
There are four species of bears in China: the Asiatic Black Bear, Brown Bear, Giant Panda and Sun Bear. Illegal hunting
and trade is a threat to all bear species in China.
Figure 5
Mainland China in relation to other areas of the study region
National legislation
Domestic trade of bear bile is legal in mainland China (Loefer et al., 2009; Phillips and Wilson, 2002). The Asiatic
Black Bear is the only species allowed for bear farming, and animals are supposed to originate only from captive bred
stocks (Robinson et al., 2007). As of April 2010; 20 of the 31 provinces in mainland China have committed to be bear
farm free (Animals Asia, 2010).
In China, only those bear bile products with specic Government approval can be legally sold in the market. Such
approval is denoted by a special label indicating that the bile is from a legal source under government management. This
approval system is managed by the Wildlife Special Mark Centre of the State Forestry Administration (SFA). The trade of
whole gall bladders in China is totally prohibited as these are known to be smuggled from the Russian Far East or poached
from the wild in China. Since 1989, it has been illegal to hunt bears or capture them from the wild for farming under the
Chinese Wild Animal Protection Law. Chapter Four of the Regulations for the Implementation of the People’s Republic of
China on the Protection of Terrestrial Wildlife (1992) discusses information regarding the breeding of protected wildlife.
15 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Article 22 states that protected wildlife may be bred in
a domestic environment for commercial purposes with
appropriate licences and breeding records. In Article
26 it states the commercial breeding of non-protected
wildlife also requires a licence and is given a limitation
quota established by the forestry department of the
relevant province. Violation of a breeding licence will
result in the conscation of the licence, animals and the
imposition of ne of up to CNY3000 (USD456) (Article
39).
Results
Of 194 TM shops surveyed in six cities in mainland
China in January and February 2011, 119 shops sold bear
bile products (Figure 5). Shops were found selling gall
bladder, raw bile, powder, pills, akes, ointment, eye
drops and suppositories (Table 5).
Table 5
Bear bile products observed in TM shops in mainland China
Discussion
The most common item observed for sale was bear bile powder which was available in nearly 80% of the shops found
selling bile products during the survey. Powder was available in bulk and by the gramme, typically it was packaged in a
bottle or set of bottles, over 22 different manufacturers of powder were recorded. Sometimes bile powder was blended
with other ingredients, with those products containing a greater proportion of bile tending to be more expensive. It was
present most often in shops in Guangdong (34) and Heilongjiang (29) and to a lesser extent in Beijing (12), Hebei (11),
Sichuan (9) and Shanghai (1) provinces or municipal cities. Over half of the shops surveyed sold powdered bile in bulk.
Gall bladders were found for sale in Guangdong, Hebei, Heilongjiang and Sichuan provinces. Four of the ve shops
selling gall bladder reported a steady customer demand and two of the shops said their customers would not consider
alternative medicines. One shop in Anguo, Hebei Province sold whole bear gall bladders said to be smuggled in from
Russia and cost USD3.80 per gramme, compared to the average USD2.37 per gramme for gall bladder from China. All
Special label indicating the bear bile within the product is
legally sourced.
© TRAFFIC East Asia
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 5 40% China
Russia
gramme - 2.37/g
Raw bile 11 100% China 5ml-15ml 1.21-8.36/ml 0.28/ml
Powder 95 65% China bulk, gramme 0.22-15.00/g 3.05/g
Pills 47 89% China packet 0.07-17.98 1.14/pill
Flakes 12 100% China packet, box 1.21-26.50 0.38/ake
Ointment 9 100% China tube 2.58-4.10 0.28/g
Eye drops 2 100% China 10ml 1.29 0.13/ml
Suppository 2 100% China packet 3.36 0.28/g
16Pills, Powders, Vials and Flakes: the bear bile trade in Asia

11 shops selling raw bile were located in Guangdong province. The bile brands observed were Daiyao, Hei Bao, Dianye
and Kerui.
Pills were available in different volumes at 45 TM shops and sold
in packets of 12 to 100 pills, with over 15 manufacturing companies
recorded. Over 20% (11 of 45) of the shops selling pills sold these in
bulk, 32% (15 of 45) reported a steady demand, and nearly 50% (23
of 45) said their customers would not consider bear bile alternatives.
Flakes were available at a number of stores, primarily in Heilongjiang
province. Boxes of akes often contained two or more ingredients
in addition to bear bile. Stores reported a steady demand but stated
that customers would consider bear bile alternatives to these products.
Four different brands of ointment, all from China, were available at
nine stores in Guangdong province; however vendors reported that
customers would not consider alternatives to this product. Two less
common bear bile products, eye drops and suppositories were also
recorded during the surveys, further emphasizing the wide variety of
bear bile products available in China.
The majority of products (99%) observed for sale in mainland China were labelled or stated to be domestically produced.
These products were said to be most often produced from the bile of farmed bears.
The bear farming industry in mainland China was sanctioned by the government in the 1980s as a conservation measure
(Feng et al., 2009). Since the introduction of commercial bear farming, the industry and market for bear bile products
has steadily increased. Presently an estimated 97 farms housing 7000 to 10 000 bears in 11 provinces remain in China
(Animals Asia 2010; MacGregor, 2010). Twenty provinces do not have bear farms; however pharmaceutical companies
do manufacture bear bile products in some of these provinces.
Bile production in China is estimated to be between 6000 kg per year (Lau, 2003) and 30 000 kg per year (Jill Robinson,
Animals Asia, in litt. to TRAFFIC Southeast Asia, April 2011). Large scale commercial farming of bears has generated
bile surpluses exceeding China’s domestic consumer demand. For example, in 1998, China produced 6357 kg of bear
bile, consuming only 4209 kg (Fan, 2000). Surpluses have led to a signicant and illegal export business. Products made
in China were consistently observed throughout the study region in Cambodia, Lao PDR, Japan, Republic of Korea,
Malaysia, Singapore, Taiwan, Thailand and Viet Nam. According to recent research conducted by Animals Asia, there are
currently 242 bear bile products and 49 UDCA products approved by the Chinese Government. In addition, 96 different
unregistered bear bile products have been observed for sale in China (Animals Asia, 2011).
China plays a signicant role in the bear bile trade as both a major producer and consumer of bile products. A majority of
the trade is domestic and legal under Chinese law. Therefore, from a legal perspective, China’s role as a major consumer
is less of a concern than its potential role as the biggest illegal source of bear bile products to countries around the world
exported in clear violation of international agreements. China’s legislation is considered Category I under the CITES
National Legislation Project; therefore current laws regulating export should be sufcient to prevent the illegal export of
bear bile products.
Bear bile medicine in China
© C. Shepherd/TRAFFIC Southeast Asia
17 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

HONG KONG SAR
Hong Kong, a Special Administrative Region (SAR) of the People’s Republic of China, is made up of three main areas:
Hong Kong SAR Island, Kowloon Peninsula and the New Territories, totalling 260 islands and a total land mass of 1104
km2. The population is over 7 million (CIA, 2011). It lies southeast of the Peoples Republic of China and 60 km east of
Macao SAR (Figure 6). The terrain of Hong Kong SAR Island is mountainous with lowlands to the north. Hong Kong
SAR’s legislation is considered Category I under the CITES National Legislation Project, meaning current legislation is
considered adequate to effectively implement CITES regulations. The Agriculture, Fisheries and Conservation Department
(AFCD) Hong Kong SAR serves as the Management Authority for CITES in Hong Kong SAR. The Scientic Authority
is the Endangered Species Scientic Commission for the People’s Republic of China, Institute of Zoology in Beijing.
Figure 6
Hong Kong SAR and Macao SAR in relation to other areas of the study region
`
Legislation
The Protection of Endangered Species of Animals and Plants Ordinance (the Ordinance) is the domestic legislation
which implements CITES in Hong Kong SAR. It replaced the Animals and Plants (Protection of Endangered Species)
Ordinance in December 2006.
Part 2 and Part 3 of the Ordinance provide for the regulation of endangered species within the CITES Appendices.
Generally, a Licence issued by the AFCD is required for the import, export, re-export or possession of a specimen of
scheduled species, including its parts and derivatives, unless otherwise provided in the Ordinance. Part 4 of the Ordinance
outlines the circumstances under which dealing in scheduled species without a licence is permitted. Specically, no
licence is required for the possession of 1) pre-Convention specimens and 2) specimens of Appendix II species which is
not a live animal or plant of wild origin.
The Ordinance further put medicines containing bear derivatives under control, as the concerned species are specied in
either Appendix I or Appendix II. Existing stock was registered in 2006 and allowed to be traded under licence.
18Pills, Powders, Vials and Flakes: the bear bile trade in Asia

The Hong Kong SAR gall bladder registration scheme requires that all gall bladders in TM outlets be registered and
licenced. The export, import, sale and possession of bear bile/gall bladders has been prohibited without a licence since
1994 (Mills et al., 1995).
Results
A total of 20 shops were surveyed in Hong Kong SAR in January, 2011. Of these, 13 were observed selling bear bile
products, specically gall bladders and pills (Table 6). Three shops were found selling gall bladders and a total of nine
gall bladders were recorded. Only one shop reported a steady demand for the product and one shop said customers would
consider alternative medicines.
Table 6
Bear bile products observed in TM shops in Hong Kong SAR
Pills were the most prevalent bear bile product found in Hong Kong SAR and these were generally sold in boxes of 50,
100 or 200. One high-priced exception was Japan Golden Ki-O pills which were sold at USD36 for a packet containing
two pills. Thirteen shops (93%) reported a steady demand and ten shops (71%) said that their customers would consider
alternative products.
Discussion
Bear gall bladders on sale in Hong Kong SAR were signicantly more expensive than those observed in mainland China;
an average of USD44.50 per gramme compared to USD2.37 per gramme in mainland China. Previous research in 1995
found four of 61 TM shops sold gall bladders with prices ranging from USD20 to USD45 per gramme (Mills et al.,
1995). Prior to this in 1991, surveys recorded more than 100 gall bladders for sale in 20 TM shops in Hong Kong SAR.
Comparing this information with the current dataset indicates although the trade in bear gall bladders has shrunk over
time, a small high-priced market persists in Hong Kong SAR.
Pills were the most commonly observed bear bile product in Hong Kong SAR and sold at an average USD0.59 per pill,
which is comparatively cheaper than pills sold in mainland China. Most pills were openly displayed and, where origin
could be determined, where purportedly produced by Japanese manufacturers. Pills were mostly sold in packets of 50
to 200 pills. The product name of the pills nearly all contained the words ‘heart tonic’, suggesting that these medicines
are thought to be good for the heart, an area of the body which is not commonly associated with bear bile use. Some
medicines of purported Japanese origin that are sold in Hong Kong SAR, such as ‘Kyushin’, have replaced bear bile with
other animal bile (such as pig) in the active ingredients. It is possible that TM shop owners stated a product contained
bear bile when in fact it contains other (non-protected) animal bile.
Since 2000, the UNEP-WCMC CITES trade database records a total of 1302.8 kg of wild-sourced gall and gall bladder
from Brown Bears has been imported to Hong Kong SAR for commercial trade exported by, or reported to originate
from, Russia. The legality of the products observed in Hong Kong SAR during these surveys could not be determined,
however it should be noted that all cross-border trade without proper import/export permits is an infraction of CITES
trade regulation agreements; therefore any bear bile found for commercial sale in Hong Kong SAR that was imported
without proper documentation is illegal. A small niche market for bear bile remains in Hong Kong SAR. In the context of
the region it would appear Hong Kong SAR plays a role as an importer of bear bile medicines for domestic consumption.
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 3 67% unclear whole
gramme
2000/whole
41-48/gramme 44.50/g
Pills 12 100% Japan box 0.34-0.91/pill 0.54/pill
19 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

MACAO SAR
Macao, a Special Administrative Region of the People’s Republic of China, is a small area with a total land mass of 28.2km2
and over 500 000 inhabitants (CIA, 2011). It is located south of Guangdong province at the mouths of the Zhujang and
Xijiang rivers (Figure 6). The narrow peninsula is primarily at, with some steep hills. Macao SAR’s economy is heavily
reliant on tourism and gambling. Macao SAR’s legislation has been assessed as Category II under the CITES National
Legislation Project indicating that it is not considered to meet all the requirements for proper implementation of CITES.
The Foreign Trade Management Department Economic Services of the People’s Republic of China Macao SAR Special
Administrative Region serves as the Management Authority for CITES. The Scientic Authority is the Endangered
Species Scientic Commission for the People’s Republic of China, Institute of Zoology in Beijing.
Legislation
Macao SAR has independent domestic legislation regarding the implementation and enforcement of CITES. Appropriate
CITES documents are required to accompany shipments of CITES-listed species between Macao SAR and mainland
China and Hong Kong SAR.
Results
Of the 10 TM shops surveyed in Macao SAR in February, 2011, none were observed to offer bear gall bladder or bile
products for sale. No bear farms were surveyed in Macao SAR as none are currently known to exist.
Discussion
The ndings of this research contrast sharply with previous research conducted in Macao SAR. In 1995 TRAFFIC
researchers visited 43 TM shops and found that 34 stocked bear gall bladder and powder with a broad price range of less
than USD1 to nearly USD70 dollars per gramme (Mills et al., 1995). These ndings indicated a shift in trends in the
mid-1990s with Macao SAR having more bear bile products than Hong Kong SAR, possibly due to the application of less
restrictive laws in Macao SAR at the time.
During recent surveys, six of the 10 shops stated it was illegal to sell bear bile medicines in Macao SAR. One shop offered
heart tonic pills containing ox and pig bile as an alternative. Two shops directed the surveyor to go to mainland China or
Hong Kong SAR to purchase bear bile medicines.
Current survey data would indicate that Macao SAR’s role in bear bile trade has diminished signicantly in recent years;
however it is difcult to determine if the level of trade has declined from a lack of consumer demand or an increase in the
effectiveness of enforcement.
20Pills, Powders, Vials and Flakes: the bear bile trade in Asia

TAIWAN
Taiwan is an island of 35 980 km2 and over 23 million people, 1.16% of which live below the poverty line (CIA, 2011). It
is located off the south coast of mainland China in the western Pacic Ocean (Figure 7). The terrain comprises mountain
ranges from the north to south, surrounded by hills and large coastal plains. Taipei is the island’s capital.
Figure 7
Taiwan in relation to other areas of the study region
Legislation
The Wildlife Conservation Act of Taiwan (1994) describes legislation pertaining to the protection of wildlife. Article 16
states that protected species and their products should not be traded, abused, killed, displayed, bred or raised, nor imported
or exported; unless under special circumstances recognized in that or related legislation1. Prior approval from the National
Principal Authority is required in order to import or export products containing protected wildlife. Furthermore, if labels
of merchandise are falsely labelled to hide the containment of protected wildlife, a ne of TWD150 000 to TWD750 000
(USD5071 to USD25 355) can be incurred. All bear species, including the Asiatic Black Bear, are listed as Protected
Species. Therefore the import, export, trade, possession or public display to sell Asiatic Black Bear gall bladders is
prohibited (Mills et al., 1995). The import and export of CITES-listed species between Taiwan and mainland China is
also regulated and appropriate documents are required to accompany shipments.
Results
Of the 64 TM shops surveyed in January and February 2011, 26 sold bear bile products (40%). These shops were
concentrated in Kaohsiung (10) and Taichung (10) and to a lesser extent in Taipei (6). The only product observed in
Taiwan’s TM shops was bear bile powder which could be mixed and compounded into pill form (Table 7).
21 Pills, Powders, Vials and Flakes: the bear bile trade in Asia
1 Although Taiwan is not a Party to CITES, it has legislation to implement the Convention, and designated competent authorities to handle
CITES-related issues.

Table 7
Bear bile products observed in TM shops in Taiwan
Discussion
Powder was often sold as a compound medicine combined with other powders commonly including: pearl, amber
(succinum), musk, stalactitum, cinnabaris and borneol. Recommendations for the best composition mixture varied
between shops. The trade name for this product is ‘Wu Bao San’ meaning ‘ve treasure powder’. Prices varied according
to the perceived quality of the bear bile powder. Powder was sold in units of 100 to 150 g as well as in bottles of ‘qian’
(3.75 g) and ‘liang’ (37.5 g). Two shops also offered alternatives: a form of Wu Bao San without bear bile or snake bile
as a substitute.
A majority of the shops had been open for more than two decades and nearly all (77%) reported a steady demand for bear
bile. All powder was said to be from mainland China, Hong Kong SAR or an undeclared source.
In a 2002 survey of TM shops in Taiwan, 30% of the 201 shops visited either sold or claimed that they could acquire
bear bile products (Chen et al., 2002). Products observed during these surveys included gall bladder, powder and other
manufactured products containing bile. Comparing this survey with the situation found during the current survey indicates
the variety of bear bile medicines available in Taiwan has decreased, however the proportion of shops selling may have
increased.
Overall, Taiwan continues to play a role in bear bile trade as a consumer of bear bile products. The availability of bear bile
products from mainland China should be taken seriously by the relevant authorities, including the Taiwanese enforcement
agencies and judiciary.
Available
Product
# Shops
Selling
Product
Open Display
% of Shops Product Origin Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Powder 26 23% mainland China
Hong Kong SAR
undeclared
gramme 2.25-18.00 0.08/g
22Pills, Powders, Vials and Flakes: the bear bile trade in Asia

JAPAN
The archipelago of Japan covers a total land area of over 370 000 km2 with a population of over 26 million, 15.7% of
which are below the poverty line (CIA, 2011). Japan is located south-east of the Russian Far East and north-east of China
(Figure 8). The major islands are Hokkaido, Honshu, Shikoku and Kyushu. The capital city Tokyo is located on the east
of the island of Honshu. Japan became a Party to CITES in 1980. The country’s legislation has been assessed as Category
I under the CITES National Legislation Project. The Trade and Economic Cooperation Bureau Ministry of Economy,
Trade and Industry is the CITES Management Authority. The Wildlife Division of the Ministry of the Environment is the
CITES Scientic Authority.
Two species of bears are native to Japan: the Asiatic Black Bear and the Brown Bear. The Brown Bear is restricted to
the northern island of Hokkaido (Mano, 2006) and the Asiatic Black Bear is found on the islands of Kyushu, Shikoku
and Honshu (Hazumi, 1999), though it is very likely extinct on Kyushu Island (Ishii, 2007). Bear parts, including
gall bladders, meat, fat and fur are utilized in Japan, although only the gall bladders are considered to have economic
importance (Ishihara, 2006).
Figure 8
Japan in relation to other areas of the study region
National legislation
CITES Appendix I-listed species including both Asiatic Black Bears and Brown Bears are listed as International
Endangered Species of Wild Fauna and Flora (IES) in the Law for Conservation of Endangered Species of Wild Fauna
and Flora (1992), also known as LCES. This listing was established in accordance with CITES to regulate trade. The
law and the Cabinet Order for the Implementation of the LCES require persons trading in fur or skin products to register
these as ‘organ’ and ‘processed article’ of IES. Bear gall bladders are not dened as ‘parts and products’ under the Cabinet
Order, therefore trade in these is not regulated. Further, bears legally taken within Japan are also excluded under the
Implementation Ordinance of the LCES. Domestic trade of bear gall bladders is regulated only by the Pharmaceutical
23 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Affairs Law, established to ensure the quality of medicinal products. Article 24 of this legislation states it is against the
law to sell or store bear gall bladders to persons unauthorized by the Ministry of Health, Labour and Welfare (Ishii, 2007).
According to the Wildlife Protection and Hunting Law (2002) and related legislation, Asiatic Black Bears and Brown
Bears may be legally hunted during specic hunting seasons in specied locations with a licence. Hunting season for the
Brown Bear is October 1 to January 31 and November 15 to February 15 for Asiatic Black Bears. There is no limit on
the number of or age of bears that can be hunted and parts of harvested bears may legally be sold with limited reporting
requirements (Ishii, 2007; Kusakari and Mano, 2006; Mano and Ishii, 2008; Moll, 2001). An estimated 2000 bears are
hunted annually (Mano and Ishii, 2008). Hunting is banned in western Honshu, Shikoku and Kyushu islands because the
populations are threatened.
Results
In February 2011, 67 TM shops were surveyed in Japan. Of these, 21 were found selling bear bile products in Osaka (11)
and Tokyo (10). Products included: bear gall bladder, powder, pills and akes (Table 8).
Table 8
Bear bile products observed in TM shops in Japan
Discussion
Nearly one third of the stores found to be selling bear bile products during the survey had been doing so for at least a
decade. From the survey, it was not established whether shop owners were able to supply bear bile products in bulk and
only one shop reported a steady customer demand. Five shops said that customers consider bear bile alternatives and
several shops recommended alternatives because bear bile products are relatively expensive in Japan. Two shops told
visitors that the clientele interested in bear bile were mostly elderly and people with a special interest in TM.
The most expensive products observed were powder and akes, reportedly originating from Japan and China, while the
least expensive products were bear bile pills. The brand ‘Seiju’ was the highest priced at USD91.50 for a 10-pill pack.
The second most expensive was ‘Yuujin-Gan’ at around USD60 per pack, followed by ‘Rokushin-Gan’ at USD25 per
pack and ‘Taan’ at USD13.32 for an 18 pill-pack. There was no stated origin for any of these products with the exception
of the Rokushin-Gan pills, which reportedly came from Japan.
Few gall bladders were observed openly on sale; however several stores said it was possible to place a special order for the
product. Prices for gall bladders were high and one shop owner conrmed gall bladder has been an expensive commodity
for a long time. Two shops reported their gall bladders were domestically sourced in Japan.
There are no bear farms producing bear bile in Japan. Japan does have a number of bear parks which function in a similar
capacity as zoos or circuses. Legislation regulating the disposal or use of parts from deceased bears at bear park facilities
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 4 25% Japan
unclear
gramme 76.83-121.96/g 109.70/g
Powder 6 33% China
Japan
gramme 61.46-268.30/g 153.09/g
Pills 12 90% China
Japan
packet box 0.43-9.15/pill 3.43/pill
Flakes 6 0% China
Japan
gramme 36.59-181.80 135.00/g
24Pills, Powders, Vials and Flakes: the bear bile trade in Asia

is unclear. In the early 1990s, ve bear parks surveyed in Japan stated they sold bear gall, however these locations did not
all sell products sourced from resident bears (Mills and Servheen, 1991). In August 1999, bear parks contacted during a
telephone survey stated that they do not sell bear bile products (Ishihara, 2005).
In February and March of 2011, four Japanese ‘bear park’ facilities were visited. One of these contained 99 Hokkaido
Brown Bears Ursus arctos yesoensis and one Asiatic Black Bear. This facility was similar to a zoo; it was open to the
public, captive breeding took place, the facility worked with local universities and deceased bears were incinerated. The
second facility housed 80 Hokkaido Brown Bears all of which were reportedly captive-bred. Similar to the rst facility,
all bears are reportedly incinerated post mortem. The third facility housed a variety of wild and domestic animals. This
facility advertised the presence of 250 individuals of nine different bear sub-species declared to be: European Brown Bear
Ursus arctos arctos, Grizzly Bear Ursus arctos horribilis, Himalayan Black Bear Selenarctos thibetanus laniger, Kodiak
Bear Ursus arctos middendori, Polar Bear, Sloth Bear, and Tibetan Bear Ursus arctos pruinosus. This park reported
that its bears produced between three to six cubs per year and stated that these were on display to the public. The fourth
facility housed around 100 individuals and was the only location that reportedly sold bear products. Products said to
contain bear bile were found on sale and included ‘bear oil cream’ sold for USD12 per 20 grams and a ‘bear energy drink’
USD3.70 per 100ml. Shop workers stated that the energy drink on sale contained bear bile extracts, but said that the bear
products on sale in the shop were produced from wild animals rather than from the bears on the premises.
Similar to previous market surveys (Ishihara, 2005), current research suggests a decreasing level of trade but a continued
market for bear bile products in Japan. Decreasing demand is likely attributed to high product cost and an abundance of
cheaper alternative medicines. Japan plays a dual role as both consumer and producer of bear bile products. As discussed
in other chapters within this report, many products purported to be from Japan were observed in TM shops outside that
country. If such products have been exported from Japan without appropriate permits, this would indicate the presence of
an illegal cross-border trade of bear bile products out of the country in violation of CITES.
25 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

REPUBLIC OF KOREA
The Republic of Korea is located on the southern half of the Korean peninsula bordered by DPR Korea, the Sea of Japan
and the Yellow Sea (Figure 9). The total country covers an area of 99 720 km2, with a population of over 48 million,
15% of whom live below the poverty line (CIA, 2011). The terrain is made up of mostly hills and mountains with wide
coastal plains in the west and southern regions. Seoul, the nation’s capital, is the largest city. In 1993, the Republic of
Korea became a Party to CITES. Their legislation meets the requirements for the implementation of CITES and has been
assessed as Category I in the CITES National Legislation Project. The Global Environment Division of the Ministry of
Environment serves as the CITES Management Authority. The Vertebrates Research Division of the National Institute of
Biological Resources serves as the CITES Scientic Authority.
Two species of bear; the Asiatic Black Bear and the Brown Bear, are native to the Republic of Korea. However, due to
intense hunting and habitat loss, both are seriously threatened with extinction (Han, 2006). While the Republic of Korea
has over 1000 bears on farms, less than 20 individuals are estimated to survive in the wild (Frances, 2009; Sudworth,
2010; WSPA, 2010).
Figure 9
The Republic of Korea in relation to other areas of the study region
National legislation
The Republic of Korea lists the Asiatic Black Bear in Category I in the list of Endangered Species of Wild Fauna and
Flora (Protection of Wild Fauna and Flora Act (2005); Ministry of Environment Republic of Korea, 2008). Category I
includes species facing extinction due to human and natural factors. Penalties for the illegal poaching and capture of listed
species include nes of up to KRW3 million (USD2752) and/or imprisonment for up to ve years. The Law of Natural
Environment Conservation covers the conservation of biodiversity and categorises both protected areas and species.
Bear farming is currently legal under present legislation. The Bear Farm Administration Index (2005), published by the
Ministry of Environment, contains guidelines on a variety of topics including: management, inspection, registration of
bears, and husbandry guidelines. The extraction of bile from live bears has been prohibited in the Republic of Korea since
26Pills, Powders, Vials and Flakes: the bear bile trade in Asia

1992. Bears on farms can be slaughtered for their parts once they reach a minimum of 10 years of age.
Recently in September 2010, the Ministry of the Environment met with national and international NGOs (including:
WSPA and Green Korea United (GKU)) to discuss the phasing out of bear farms. This initiative has resulted in the
presentation of a bill to Parliament. With adequate support of this bill, a policy to end bear farming is thought to be a
likely possibility, however as of March 2011, no decision on this bill had been made.
Results
In February 2011, TM shops were surveyed in the Republic of Korea. Of the 61 shops surveyed in Daegu, Seoul and
Seoungnam;, 26 sold bear bile, primarily in whole gall bladder form (Table 9).
Table 9
Bear bile products observed in TM shops in the Republic of Korea
Over 50% of the gall bladders found in Korean TM shops were claimed to be of Russian origin; 38% were claimed to be
from China and 7% were claimed to be domestically sourced. Ten of the 26 shops (38%) reported a steady demand for
bear bile and the majority of shops (77%) said that their customers would not consider alternative products.
Discussion
Results suggest that bear products are a highly priced commodity in the Republic of Korea, especially in comparison to
other countries in the region. In Seoul, gall bladders from both wild-caught bears from Russia and captive-bred bears
from China were offered for sale, with prices ranging from USD16 to USD160 per gramme. In addition, one shop also
sold bear bile akes that were purportedly from China and Russia and cost USD96 per bottle. Four of ve shops in
Seoungnam stated they could order bear gall bladder with reported prices ranging from USD1200 to USD3600. Sixteen
of 23 shops surveyed in Daegu sold gall bladder, however shop owners stated it was difcult to nd domestic gall bladder;
therefore stock was often sourced from Russia and China. Prices for gall bladders ranged from USD9 to USD24 per
gramme and from USD480 to USD1200 for a whole gall bladder. Flakes from China were also observed and these sold
for USD160 per bottle.
Conversations with shop owners revealed that many were aware that selling imported bear bile products without CITES
permits was illegal. They reported that products could easily be ordered in advance from a dealer and a few even
recommended making a pre-order for wild caught bears in an effort to guarantee authenticity. Concerns over authenticity
were reported by many shop owners, and some stated they would not sell bear gall bladder because it was too difcult to
distinguish it from other species. Issues with authenticity and the practice of ordering products through dealers may be a
factor in the broad and expensive price range documented in the Republic of Korea.
There appeared to be preference for wild-sourced bears from Russia as Chinese medicines were thought to be ‘unreliable’
or of lesser quality; possibly explaining why other products such as pills or powder were not observed in TM shops. One
shop owner reported that sales of wild Russian gall bladder for USD42 per gramme are permitted in a single import by
the Ministry of Health and Welfare; however this statement has not been conrmed.
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form) Price Range (USD) Average Price
(USD)/Unit
Gall bladder 25 0% China
Rep. Korea
Russia
whole
gramme
whole: 480.00-3600.00
gramme: 9.00-240.00
1856.00/whole
55.38/g
Flakes 2 0% China
Russia
bottle 96.00-160.00 128/bottle
27 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

As of February 2011, there were 59 bear farms in the Republic of Korea housing 1066 bears, according to the Ministry
of the Environment. Of these, there were 992 Asiatic Black Bears, 57 American Black Bears Ursus americanus and 17
Brown Bears. It is illegal to extract the bile from captive bears or to kill and remove the gall bladders from bears under 10
years of age. No domestic Korean bear bile products were observed in this survey in the Republic of Korea or the other
countries/territories surveyed in this report. This raises the question that if these farms do not produce bile, why do they
persist in the Republic of Korea? The answer to this question is not apparent; however a likely possibility is that bile is
illegally extracted and sold directly through the farms, giving buyers the guarantee of authenticity clearly prioritized by
Koreans consumers (Chris Gee, WSPA, in litt. to TRAFFIC Southeast Asia, April 2011). In a 2007 survey of Korean
bear farmers conducted by Green Korea United, 80% of farmers agreed to abolish bear farms if the government agreed to
purchase their bears and compensate farmers for their business at an average price of USD11 350 per farm .
Korean tourists in China and Viet Nam are known to be major consumers of bear bile medicines. Hundreds of Korean
tourists are said to visit bear farms in Ha Long Bay and Quang Ninh, Viet Nam, alone; tasting and purchasing bile
products to take home (ENV 2008; ENV 2010; Vu, 2010). In addition, Korean consumers have been known to frequent
farms in Jilin, China (Jill Robinson, Animals Asia, in litt. to TRAFFIC Southeast Asia, April 2011). The Republic of
Korea appears to play a signicant role as a consumer of predominantly wild bear gall bladder in East Asia.
28Pills, Powders, Vials and Flakes: the bear bile trade in Asia

LAO PDR
Lao Peoples Democratic Republic is a landlocked country of 236 800 km2 with a population over 6 million, 26% of whom
live below the poverty line (CIA, 2011). It is located in the centre of Indochina bordered by Cambodia, China, Myanmar,
Thailand and Viet Nam (Figure 10). The terrain is heavily mountainous with the majority of the western border delineated
by the Mekong River. The Mekong serves as a major transportation route. Due to the country’s strategic location, it is
a key crossway for trade between the neighbouring countries. Lao PDR became a Party to CITES in 2004, the country’s
legislation has been assessed through the CITES National Legislation Project as being Category III meaning that it does
not meet the requirements necessary to implement CITES properly. The Ministry of Agriculture and Forestry serves as
the CITES Management Authority and the role of the CITES Scientic Authority is conducted by the National Science
and Technology Agency Research Institute of Science.
There are two species of bears in Lao PDR: the Asiatic Black Bear and the Sun Bear.
Figure 10
Lao PDR in relation to other areas of the study region
National legislation
The Wildlife and Aquatic Law (2007) allows for the trade of wildlife and aquatic life from second generation animals with
proper approval and permission. This law denes products as ‘extracted parts of wildlife and aquatic life for producing
like medicine for healing illness, ornamental and other utilization purposes’.
Results
Six of 37 TM shops surveyed in September and October 2010 were observed selling bear bile products including gall
bladder, raw bile and pills (Table 10).
29 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Table 10
Bear bile products observed in TM shops in Lao PDR
A total of 102 bears on four farms were observed in Lao PDR from September to November 2010. Of these, there were 98
Asiatic Black Bears and four Sun Bears (Table 11). Three of four farms surveyed sold bear bile in powdered gall bladder
form, with prices averaging USD16.60 per millilitre.
Table 11
Data from bear farms surveyed in Lao PDR
Discussion
Pills were the most commonly sold product, openly displayed and purportedly from China, manufactured under the trade
names Xiong Tan Tieh Ta Wan and Thonghua Dieda Wan. Gall bladders from China were sold either by the piece, which
could be compounded into medicine, or as a whole. Raw bile from the Truong Son Coecco Tourist Company in Viet Nam
was available by cubic centimetres (cm3) at one location. All shops selling bear bile products reported a steady customer
demand for these products. It is interesting to note that all products observed in TM shops were cross-border-sourced, in
violation of international trade agreements, despite the fact that Lao PDR has its own bear farms which produce raw bile.
None of the four farms surveyed were reportedly owned by a
Laotian; three were allegedly owned by Vietnamese and one by
a Chinese. Three of the four farms also housed other wildlife
including tigers, lions, gibbons and macaques. None of the facilities
had captive breeding programs and one farmer reported high death
rates due to disease. Therefore it can be reasonably assumed that
replacement stock is sourced from the wild. Boten, the location of
one farm surveyed, is a Special Economic Zone bordering China
and is a known trade hub for wildlife export from Lao PDR to
China (Allen, 2009; Ghosh, 2010). This small city is known to
have many TM shops selling bear bile and other protected wildlife
products; including tiger parts and ivory (Ghosh, 2010). Many of
the farms found in Lao PDR are currently owned by foreigners in
areas such as Boten. The country may be a burgeoning location
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 1 0% China ground - -
Raw bile 1 0% Viet Nam 1ml vial 6.24/ml 6.24/ml
Pills 4 100% China single
packets
- 1.50/pill
Farm Location # of Asiatic
Black Bears # of Sun Bears Product Price (USD)
1 Boten* 19 1 raw bile 6.64/bottle
2 Vientiane 21 3 raw bile 16.60/ml
3 Luang Prabang 8 - raw bile 16.60/ml
4 North of Thakhek 50 - - -
Asiatic Black Bear on a bear farm in Luang Pra-
bang, Lao PDR
© A. Oswell/TRAFFIC Southeast Asia
*Subsequent surveys found 16 Asiatic Black Bears and 0 Sun Bears at this location (Louis Ng, ACRES, in litt. to TRAFFIC
Southeast Asia, April 2011).
30Pills, Powders, Vials and Flakes: the bear bile trade in Asia

for the establishment of bear farms; especially as pressure to close farms in China and Viet Nam increases.
Wild-caught bears from Lao PDR have been used to
replenish farm stocks in neighbouring countries (Hunt,
2009; MacGregor, 2010). Although bear farming in
Lao PDR takes place on a smaller-scale than in China,
the Republic of Korea and Viet Nam; a small number
of farms have been established in the country over
the last decade. This trend is cause for concern as
laws regulating bear farming and bear bile trade are
relatively lax in Lao PDR, making the country an
attractive potential location for future bear farms.
Lao PDR plays a burgeoning role in the bear bile trade
as both a consumer and producer of bear bile products.
Steady local demand for bear bile products encourages an illegal import trade from nearby countries such as China and
Viet Nam. Lax wildlife trade laws in the country make bear farming extremely difcult to regulate and discourage.
Bear farm advertisement in Luang Prabang, Lao PDR
© A. Oswell/TRAFFIC Southeast Asia.
31 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

MALAYSIA
Malaysia’s total land area covers over 329 500 km2 with a population of over 28.7 million, 5.1% of which are below
the poverty line (CIA, 2011). The country is split between two distinct land masses, Peninsular and East Malaysia.
Peninsular Malaysia is located to the south of Thailand and north of Singapore, whilst the eastern States of Sabah and
Sarawak lie across the South China Sea on the northern part of Borneo Island. In 1978; Malaysia became the rst South-
east Asian country to become Party to CITES. The country’s national legislation has been categorised as Category 2
under the CITES National Legislation Project, however recently there have been revisions to the wildlife legislation.
The Ministry of Natural Resources and Environment (NRE), Forestry Development Division, serves as both the CITES
Management and Scientic Authorities. It should be noted that Peninsular Malaysia and the East Malaysian States of
Sabah and Sarawak each have their own wildlife legislation.
Only one species of bear, the Sun Bear, is native to Malaysia.
Figure 11
Malaysia in relation to other areas of the study region
National legislation
Peninsular Malaysia
The Wildlife Conservation Act (2010) was recently passed, replacing the previous Wildlife Protection Act (1972). The
2010 Act includes all bear species as Totally Protected animals. Species which are listed as Totally Protected may only
be traded for non-commercial purposes, pending Ministry permission and approval. The new act also imposes harsher
penalties; with those found hunting or keeping protected females or young animals of a totally protected species being
liable to a ne of up to MYR100 000 (USD32 905) and/or a maximum jail sentence of up to ve years. Penalties for
those who hunt or keep protected male animals may incur nes of up to MYR50 000 (USD16 452) and/or a maximum
jail sentence of up to two years.
The International Trade in Endangered Species Act (2008) was created to allow full implementation of CITES in Malaysia.
32Pills, Powders, Vials and Flakes: the bear bile trade in Asia

The import or export of any species listed in the schedules requires valid permits, and registration for the breeding of such
species is also required. Fines for the possession of CITES-listed species are up to MYR100 000 (USD32 905).
Sabah
The Sun Bear is listed as a Totally Protected species in Section 25(1) of the Sabah Wildlife Conservation Enactment
(1997). No person is to hunt any animal species listed in Part I Schedule I. No person is to possess Part I of Schedule I
animals or their products without written permission. The purchase, sale, import and export of protected animal species
and/or their products is prohibited. Fines for possession of Totally Protected species include up to MYR50 000 (USD16
452) and/or imprisonment of up to ve years.
Sarawak
Sun Bears are listed as Protected Animals under the Wild Life Protection Ordinance (1998). This list covers all species
listed in Appendices I and II of CITES. Part 4, section 29(2) states that it is forbidden for any person to hunt, kill, capture
or sell any protected animal, their parts or derivatives, unless in accordance with a special licence.
Results
Peninsular Malaysia
In November and December of 2010, 137 TM shops were
surveyed in Penang, Perak, Johor, Kelantan, Selangor and
Kuala Lumpur. A total of 101 shops were found to be
selling bear bile products in various forms including gall
bladders, pills, akes and ointments (Table 12).
Table 12
Bear bile products observed in TM shops in Peninsular Malaysia
Available
Product
# Shops
Selling
Product
Open
Display
% of Shops
Product
Origin Sold In Price Range (USD) Average Price
(USD)/Unit
Gall bladder 14 0% Malaysia
Indonesia
China
Thailand
Viet Nam
Nepal
whole
gramme
163.21-261.31/whole
0.33-13.09/gramme
212.26/whole
4.78/g
Pills 87 25% China
Malaysia
Singapore
packet 0.10-1.96/pill 0.56/pill
Flakes 6 17% China bottle 6.55-29.00/bottle 17.87/bottle
Ointment 1 0% China tube - 0.15/g
Vials of bear bile powder observed for sale in Johor Bahru,
Malaysia
© C. Yeong/TRAFFIC Southeast Asia
33 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Sabah
Twenty-one shops were surveyed in Kota Kinabalu in December 2010. Eight of these sold bear bile products in gall
bladder and pill form (Table 13).
Table 13
Bear bile products observed in TM shops in Sabah, Malaysia
Sarawak
Of 54 TM shops surveyed in Miri, Kuching and Sibu in December 2010, 15
shops sold bear bile products including gall bladder, pills, akes and ointment
(Table 14).
Table 14
Bear bile products observed in TM shops in Sarawak, Malaysia
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form) Price Range (USD) Average Price
(USD)/Unit
Gall bladder 12 8% Sarawak whole piece 16.00-222.84/whole
12.45-16.38/piece
89.00/whole
13.86/piece
Pills 1 100% Malaysia box - 0.32/pill
Flakes 1 100% China bottle - 13.10/bottle
Ointment 1 100% China bottle - 8.19/bottle
Discussion
Of the total shops surveyed in Peninsular Malaysia, 77% sold bear bile products. Over 30 gall bladders were seen across
four States: Johor, Penang, Selangor and Kelantan. Interviews with TM shop staff revealed that a majority of the gall
bladders were wild-sourced. Four shops surveyed claimed that gall bladders were sourced from Indonesia, a country
of origin not reported in any other surveyed location. Pills were the most commonly observed item and were sold in
packets of 10 to 400 pills, with the bear bile sometimes mixed with other ingredients, such as pearl. In addition, akes
and ointment were seen in small quantities. Many of the shop owners and staff were aware that selling bear bile products
was illegal.
Available
Product
# Shops
Selling
Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average Price
(USD)/Unit
Gall bladder 3 0% Sabah gramme
piece
148.00/piece 5.25/g
Pills 5 40% Malaysia
China
pill 0.16-0.32 0.26/pill
Haemorrhoid ointment containing bear bile.
Manufactured in China, for sale in Penang,
Malaysia
© C. Yeong/TRAFFIC Southeast Asia
34Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Bear bile pills and gall bladders were the only products
observed in TM shops in Sabah. A total of 15 gall bladders
were observed in three TM shops, all of which were dried.
Two shops said their current stock was several years old.
One shop owner reported that their customer base used to
be primarily Korean and Japanese individuals; however
in recent years these had been replaced by local Chinese.
The pills on sale were nearly all manufactured by a
pharmaceutical company said to be in Selangor, Malaysia.
Sarawak had the highest proportion of gall bladders
observed in Malaysia at a total of 115. All of the gall
bladders were dried and a majority, if not all, were several
years old; some were reported to be 10 to 12 years old.
Discussions with TM shop staff indicated that customers
had a strong preference for wild bear products and noted
that gall bladders are more difcult to obtain now than in
the past. One shop also commented that their past customer base was mostly Taiwanese and Korean. At one shop in Miri,
the shop owners stated they usually had whole dried bear gall bladders on display and foreigners, particularly Koreans
and Taiwanese, were their main customers.
In surveys conducted in 2002; nearly 78% of TM shops surveyed in Malaysia sold bear bile products in the form of gall
bladders, powder and pills (Pereira et al., 2002). Of this, 72% of the products were said to be from China. Results from
the 2010 survey conrm a similar proportion of shops selling bear bile,
but with relatively fewer (55%) of those products being from China.
There appears to be a substantial percentage of products available which
are reportedly of Malaysian origin (28%).
Due to the reported preference for wild-sourced gall bladder as well as a
signicant presence of domestically sourced gall bladders in Sabah and
Sarawak, consumer demand for wild gall bladders may be a concern.
However, much of the stock observed was several years old and some
shop owners reported a shift in clientele away from international
customers. Therefore, while this trend is a concern, it is difcult to
estimate the potential impact on wild populations without knowing stock
turnover rates.
In general, the hunting of bears in Malaysia is a concern as there appears to be a consumer demand for many kinds of wild
bear products including but not limited to, bear bile. From 2005 to 2009, 11 seizures of bear parts representing a minimum
of 33 Sun Bears were made in Peninsular Malaysia alone (Shepherd and Shepherd, 2010).
Malaysia plays a dual role in the bear bile trade as a consumer as well as a producer. The high percentage of shops openly
selling bear products indicates a market demand and little enforcement effort to discourage shops from providing the
product. Malaysia’s role as a producer may be changing in recent years from the small-scale provision of products to East
Asian tourists, to a potentially commercialized production business.
Gallbladders purported to be from Sun Bears in a TM shop
in Kota Kinabalu, Sabah, Malaysia
© C.Yeong/TRAFFIC Southeast Asia
Bear bile product from China observed for
sale in Melaka, Malaysia.
© C. Yeong/TRAFFIC Southeast Asia
35 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

MYANMAR
Myanmar is the largest country in mainland South-east Asia
with a total land area of over 676 500km2 and a population of
nearly 54 million, 32.7% of which live under the poverty line.
It is bordered by China, Bangladesh, India, Lao PDR and
Thailand (Figure 12). The capital city, Yangon, is located in the
south. The terrain is made up of central lowlands surrounded
by steep mountains. Today, vast forested areas that house
potentially large populations of both Asiatic Black Bears and
Sun Bears still remain (Servheen et al., 1999). Myanmar
became a Party to CITES in 1997. Current legislation has
been rated as Category III by the CITES National Legislation
Project meaning it is not considered to meet the requirements
necessary to properly implement CITES. The Director
General of the Forest Department, Ministry of Forestry
serves as the CITES Management Authority and the Director
of Nature and Wildlife Conservation Division, Forest
Department serves as the CITES Scientic Authority.
There are two species, the Asiatic Black Bear and the Sun
Bear, native to Myanmar.
National legislation
The Protection of Wild Life and Wild Plants and Conservation
of Natural Areas Law (1994) prohibits the hunting and killing
of protected animals without permission. Possession, selling,
transport or transfer of wildlife and wildlife parts is prohibited
along with commercial transactions. Violations of these laws
include imprisonment of up to three years (for Asiatic Black Bear) or seven years (for Sun Bear) or nes up to USD450
(Asiatic Black Bear) or USD1490 (Sun Bear). The List of Wildlife Protected from the Forest Department lists the Sun
Bear under Totally Protected Wild Animals and the Asiatic Black Bear under Protected Wild Animals.
Results
In September and November 2010, 42 market stalls were surveyed in Mong La and Tachilek markets, 30 of which sold
bear gall bladder (Table 15). All were openly displayed and sold in whole form with price dependent on weight.
Table 15
Bear bile products observed in Mong La and Tachilek markets in Myanmar
Figure 12
Myanmar in relation to other areas of the study
region
Market Available
Product
# Stalls
Selling
Product
# of Gall
bladders
Observed
Product
Origin
Price Range
(USD)
Average
Price (USD)
Mong La Gall bladder 13 60 Lao PDR
Myanmar
26.61-59.88 47.73
Tachilek Gall bladder 17 45 Lao PDR
Myanmar
39.92-59.88 54.49
36
Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Two farms in Myanmar, one in Mong La and one in Pangshan city were surveyed in October 2010 (Table 16). A total of
43 Asiatic Black Bears and three Sun Bears were observed at the rst farm in Mong La, the second farm housed a total
of nine Asiatic Black Bears.
Table 16
Data from bear farms surveyed in Myanmar
Discussion
Mong La and Tachilek are wildlife trade hubs strategically placed along
the Chinese and Thai borders, respectively. As both locations are known
to be trade hubs it is likely that products, including bear parts, from these
markets are crossing borders (Shepherd and Nijman, 2008). All gall
bladders observed during the shop surveys were allegedly from Lao PDR
and Myanmar. The average price per gall bladder was slightly higher in
Tachilek than in Mong La. Each stall stocked between one and 11 gall
bladders, with an average of 3.5 gall bladders per stall. A majority of the
gall bladders observed were likely wild-sourced, as is much of the other
wildlife products found in these two markets (Shepherd and Nijman, 2008;
Oswell, 2010). It is possible some of these gall bladders said to be from
bears, were in fact those of pigs (Feng et al., 2009).
Neither of the farms surveyed stated they had captive breeding programs;
all bears were reportedly wild caught from China, Lao PDR and Myanmar.
Both facilities were Chinese owned. One farm was located in Mong La,
on the border between China and Myanmar. The second in Pangshan,
Wa State, informed surveyors of high mortality and turnover rates at the
facility. Bile products sold at the farms included an alcoholic bile tonic
priced at USD22.65 per bottle, raw bile for USD0.83 per millilitre and
capsules costing USD18.12 per box. Farm staff from the Pangkham facility stated bile products were often ordered and
supplied to customers from China and Thailand.
Our market survey results represent a minimum of 105 bears, with expected high turnover rates. Both farms housed a
total of 55 bears. With high turnover rates at these facilities, restocking from the wild is almost a certainty. It is likely
therefore, that the trade of bear products in Myanmar puts an unsustainable pressure on wild populations both in Myanmar
and surrounding countries.
Myanmar plays a critical role as a producer of bear bile products and a transit for illegal trade through wildlife trade hubs
such as Mong La and Tachilek. It is also a concern that foreigners may continue to establish bear farms in Myanmar,
especially in light of increasing pressure on China and Viet Nam to stop bear farming.
Farm Location Est. # of Asiatic
Black Bears
# of Sun
Bears Product Price (USD)
1 Mong La 1999 43 3 Bile tonic
Raw bile
Dried bear
Pills
bile tonic: 22.65/bottle
raw bile: 166.08/200ml
-
pills: 18.12/box
2 Pangshan City 2005 9 Raw bile -
Animal gall bladders at Tachilek
© TRAFFIC Southeast Asia
37 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

SINGAPORE
Singapore is located on the southern tip of the Malaysian Peninsula just one degree north of the equator (Figure 13).
This small country of 697 km2 has a population of over 4.7 million (CIA, 2011). It is heavily urbanized and the majority
of the island is no more than 15 meters above sea level. The Republic of Singapore is the 4th leading nancial centre
in the world with an important role in international trade. In 1987, Singapore became a Party to CITES. Singapore’s
legislation is Category I of the CITES National Legislation Project and considered to meet all the requirements to properly
implement CITES regulations. The Agri-food and Veterinary Authority (AVA) serves as both the CITES Management
and Scientic Authority.
Singapore has no existing wild bear populations.
Figure 13
Singapore in relation to other areas of the study region
National legislation
According to the Animals and Birds Act (2002), it is forbidden to import or export any animal without a licence. The main
purpose of this act is to prevent cruelty to animals and disease transmission (Animals and Birds Act Chapter 7, 2002).
The Wild Animals and Birds Act (Chapter 351) prohibits the import of wild animals, alive or dead or any part thereof, into
Singapore without special authorization by the Director General of AVA.
The Endangered Species (Import and Export) Act was rst established in 1989 to implement CITES by controlling the
import and export of those plants and animal species listed in the CITES Appendices. By this law, it is illegal to possess,
sell, offer or publicly display any listed species that have been imported without a permit. If violated, nes of up to
SGD5000 (USD3982) and/or a prison sentence of up to 12 months can be levied.
The Endangered Species (Import and Export) Act 2006 was revised to replace and re-enact with additional amendments
to the previous Endangered Species (Import and Export) Act. This Act was amended to extend legal coverage to the
derivatives of scheduled animals and plants, including fake specimens purported to be from CITES-listed species. The
Act was further extended to criminalize the advertising of scheduled species and covers scheduled animals and plants in
transit through Singapore.
38Pills, Powders, Vials and Flakes: the bear bile trade in Asia

The Endangered Species (Import and Export) Act 2006 empowers the AVA to grant permits for import and export of
CITES-listed species and conduct investigations on cases of suspected illegal wildlife trade. Revised penalties include a
ne of SGD50 000 (USD39 820) per scheduled species (but not to exceed SGD500 000) and/or a jail term of up to two
years.
The Medicines Act (Chapter 176) came into effect September 1999. This requires that all Chinese Proprietary Medicines
(CPM) be labelled in English with all relevant information including brand name, expiry date, ingredients and origin.
Any outlets selling CPM (referred to as TM in this report) without appropriate labels and any medicines containing bear
derivatives are acting in violation of the law (Govind and Ho, 2001).
Results
A total of 50 shops were surveyed in Singapore in October, 2010. Of these; three reportedly sold bear bile products in the
form of gall bladders and pills (Table 17). Pills were the most commonly observed product and were sold individually or
in units of 80 or 100.
Table 17
Bear bile products observed in TM shops in Singapore
Discussion
Only 6% of the TM shops surveyed in Singapore were observed selling alleged bear bile products. This contrasts sharply
with previous surveys conducted in 2001 of 68 TM shops where 50 shops (74%) were found selling purported bear bile
medicines, primarily in pill, gall bladder, ake, powder and ointment forms (Govind and Ho, 2001) and another survey
carried out in 2006 of 115 TM shops where 23 shops (20%) were found to be selling bear bile products (Ng and Tan,
2006). It would appear there has been a dramatic decrease in the amount of TM shops selling bear bile products. The
regular surveillance and monitoring of TM shops, the high penalties imposed on offenders and public outreach efforts
have contributed to the decrease in the illegal domestic bear bile trade.
Of the products that were recently available in Singapore; most if not all seemed to come from China. Three shops stated
that the pills on sale were manufactured from farmed bears in China and the only shop selling gall bladder reported that
bear bile could be ordered in bulk from China and then compounded into pills on site. None of the shops openly displayed
bear products and none of the pill containers were labelled.
Other possible reasons for the decline in bear bile products found in Singapore’s TM shops could be a decrease in domestic
demand. Alternatively, shop owners may have been apprehensive to discuss and potentially sell illegal wildlife products
to non-regular customers. Another explanation could be that recent work by NGOs on this issue has had signicant
effects. In 2007, ACRES, Animals Asia and the Singapore TCM Organizations Committee (STOC) created the ‘ACRES
and STOC Endangered Species-Friendly Labelling Scheme’. Over 300 TM shops have participated in this scheme by
committing to not sell protected wildlife.
Current research suggests that Singapore plays a very small role as a consumer of bear bile products and has little to no
presence in the market as a producer. Despite this, Singapore should still be regarded as a strategic player in the bear
Available
Product
# Shops
Selling Product
Open Display
% of Shops
Product
Origin
Sold In
(Form)
Price
Range/Unit
Average
Price
(USD)/Unit
Gall bladder 1 0% - whole - -
Pills 3 0% China
Singapore
individual
packet
0.93-2.29/pill 1.58/pill
39 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

bile trade in Asia. Due to its strategic location at the tip of Peninsular Malaysia, Singapore is a major shipping port and
is thought to be among the world’s top 10 wildlife trade hubs (Lim, 2010). As bear bile medicines produced in China are
readily available in many countries around the world, it is conceivable that shipments of bear bile products transit through
Singapore.
40Pills, Powders, Vials and Flakes: the bear bile trade in Asia

THAILAND
Thailand lies in South-east Asia with coasts on the
Andaman Sea and the Gulf of Thailand. It borders
Myanmar to the north-west, Lao PDR to the north
east, Cambodia to the south-east and Malaysia to
the south (Figure 14). Thailand has a total land
mass of over 513 000 km2 and a population of over
66.7 million, 9.6% of which live below the poverty
line (CIA, 2011). It is characterized by mountain
ranges in the north and along the Myanmar border,
with central plains. In 1983, Thailand became a
Party to CITES and its legislation has been assessed
as Category I by the CITES National Legislation
Project. The CITES ofce of the National Parks,
Wildlife and Plant Conservation Department serves
as both the Management and Scientic Authority.
Two species of bears, the Asiatic Black Bear and the
Sun Bear, are native to Thailand.
National legislation
The CITES Species List Thai Government
Announcement and the Protected Species List of
Thailand both list the Asiatic Black Bear, Brown Bear
and Sun Bear as protected. These lists are used as a
reference of protected species in accordance with the
Wild Animal Reservation and Protection Act (1992).
According to the Wild Animal Reservation and
Protection Act, the possession and trade of protected
wild animals and their carcasses is prohibited, unless
listed in Section 17 (sections 19, 20). Section 17 lists 29 protected wildlife species that can be bred; however this list
does not include bears. Violation of the Act is punishable by a ne of up to THB40 000 (USD1313) and/or up to 4 years
in prison.
Results
In August and September 2010, 78 TM shops were surveyed in Bangkok, Thailand. Of these, 33 were found to be selling
bear bile products in the form of pills, bile and gall bladders (Table 18).
Figure 14
Thailand in relation to other areas of the study region
41 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Table 18
Bear bile products observed for sale in TM shops in Thailand
Discussion
Slightly less than half (42%) of the TM shops surveyed in Thailand were found to be selling bear bile products. Pills were
most frequently observed (94%) and were openly displayed in half of the shops that carried them. Bile was observed
in nearly a third (27%) of the shops and was openly displayed nearly half of the time. Gall bladders were seen in only
two shops (6%) and were not openly displayed. Over 90% of the shops reported a steady customer demand for bear bile
products, but stated that customers were sometimes interested in alternative products.
Several TM shops sold products from more than one country/territory. Overall, 95% of shops selling bear bile reported
products came from China. Small amounts were also reported from Lao PDR (13%), Taiwan (5%), Myanmar (3%) and
domestically sourced (5%). Although our research shows only a small percentage of trade moving from Myanmar to
Thailand, the trade of bear gall bladder across the border has been previously documented. Interviews conducted with
traders in 2006 in Tachilek and Three Pagodas Pass, two major markets on the Thai-Myanmar border, stated that the
majority of their products, including bear parts, were purchased by Chinese and Thai buyers (Shepherd, 2007).
Nine shops stated they sold bile from farmed bears in China. However 13 of 33 shops (39%) claimed that their products
were from wild bears and many stated a customer preference for wild-sourced bile. Both shops selling gall bladders
claimed these had come from wild bears in China.
Thailand’s role in the bear bile trade seems to be primarily that of a consumer. Products sourced from countries bordering
Thailand were consistently observed during market surveys, indicating a signicant cross-border trade of bear products
into the country. As nearly every shop reported a steady demand for bear bile and products are not produced domestically;
it can be reasonably assumed there is a substantial level of illegal cross-border trade carrying products into Thailand.
Available
Product
# Shops
Selling
Product
Open
Display
% of Shops
Product
Origin
Sold In
(Form)
Price Range
(USD)
Average
Price
(USD)/Unit
Gall bladder 2 0% China
Taiwan
whole
gramme
- 116.09/whole
0.11/g
Bile 9 44% China
Lao PDR
Myanmar
gramme
bottle
capsule
0.33-6.63/g 3.48/g
Pills 31 52% China
Lao PDR
Myanmar
Taiwan
Thailand
individual 1.33-16.58/pill 3.83/pill
42Pills, Powders, Vials and Flakes: the bear bile trade in Asia

VIET NAM
This country prole was authored in partnership with Education for Nature Vietnam (ENV).
Viet Nam is located on the Indochinese Peninsula,
bordered to the south and east by the South China Sea,
Gulf of Tonkin and Gulf of Thailand and to the north
and west by China, Lao PDR and Cambodia (Figure
15). The nation has a land mass of approximately 331
000 km2 and a population of over 90.5 million, 10.6%
of whom live below the poverty line (CIA, 2011). It is
made up of hills, tropical lowlands and densely forested
highlands. Major rivers are the Red River Delta in the
north and the Mekong River Delta in the south. Viet
Nam became a Party to CITES in 1994. Viet Nam’s
national legislation is considered Category I under the
CITES National Legislation Project, meaning that it
meets the requirements to properly implement CITES
regulations. The Forest Protection Department (FPD)
in the Ministry of Agriculture and Rural Development
(MARD) serves as the CITES Management Authority.
The Institute of Ecology and Biological Resource
(IEBR) of the Viet Nam Academy of Sciences and
Technology (VAST), the Forestry Sciences Institute
of Viet Nam (of MARD) serve as CITES Scientic
Authorities for the country.
There are two species of bears, Asiatic Black Bears
and Sun Bears, native to Viet Nam.
National legislation
Decree 32/2006/ND-CP lists the Asiatic Black Bear
and the Sun Bear in Group 1B affording both species
full protection from commercial exploitation of any
kind. This legislation prohibits all trade, advertising,
hunting and transit.
Governmental Decree No 82/2006/ND-CP Appendix I states that wild animals, plant species, and processed parts listed
in treaties to which Viet Nam is a Party, are nationally banned for exploitation and use. This wording covers the import,
export and transit of CITES-listed species that are brought into Viet Nam or are leaving the country; however it does not
cover domestic species or specimens of unclear origin.
In 2004, Viet Nam enacted the National Action Plan to Strengthen Control of Trade in Wild Fauna and Flora. In order to
monitor numbers of captive bears on bile farms, all farm bears were micro-chipped with the intent of keeping wild bears
from entering the farmed bile trade (Nguyen, 2007).
Decision 02/2005/QD-BNN was established to manage what appeared to be the growing development of bear farming
in Viet Nam. MARD issued management regulations which required owners to register their bears, setting a cut-off
date in February 2006. Since then, all unregistered bears have been subject to conscation and bear owners are subject
to punishment. All bears are currently considered government property. However owners of micro-chipped bears are
Figure 15
Viet Nam in relation to other areas of the study
region
43 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

permitted to keep them, but the extraction of bear bile from these animals is illegal.
The Regulation of Bear Management Decision 95/2008/QD-BNN (2008) replaced Decision 02/2005/QD-BNN. However
the new legislation is weaker as it does not mention bear cubs born in captivity. This has opened up a loophole for farmers,
allowing them to claim that new cubs on farms have been born in captivity when they may in fact be wild-sourced.
Results
A total of 31 shops were surveyed in Viet Nam from September to October 2010. Of these 20 were observed selling bear
derivatives in the forms of bile, gall bladder, powder, akes and ointment (Table 19).
Table 19
Bear bile products observed in TM shops in Viet Nam
Surveys of bear farms in Viet Nam took place in September and October 2010. There are estimated to be 750 bear farms
in Viet Nam, housing around 3000 bears (ENV, 2011). At least 677 bears on 34 farms were observed during this survey.
Of these were a minimum of 671 Asiatic Black Bears and at least six Sun Bears. Bear farms varied in size from two to 60
individuals; however the average farm contained less than 10 bears, housed on residential property.
Discussion
TM shop surveys
Of the TM shops surveyed in Viet Nam, 65% sold bear bile products.
The most commonly observed product (45%) was raw bile sold
in 1cm3 vials. The second most common product was bear gall
bladder, present at a third of shops found carrying bear products
and in total, 21 gall bladders were observed between six TM shops.
Powdered bear bile was found in 20% of the TM shops, followed
by akes (15%) and ointment (5%). Only 17% of the shops openly
displayed their products for sale. Many Vietnamese products were
labelled in Chinese; possibly to increase the perceived value of the
product or to market it to Chinese tourists. These products are
thought to be either 1) produced in Viet Nam with false labelling
to deceive the buyer and increase retail sales or 2) produced in
Viet Nam for export to China; however some are retained for sale
on the local market. Over half (58%) of all bear bile products
Available
Product
# Shops
Selling
Product
Open
Display
% of Shops
Product
Origin
Sold In
(Form) Price Range (USD) Average Price
(USD)/Unit
Gall bladder 6 0% Lao PDR
Russia
Viet Nam
whole
gramme
128.20-615.00/whole
4.00-18.40/g
371.60/whole
11.72/g
Raw bile 9 22% Viet Nam vial 2.05-11.79 5.03/ml
Powder 4 25% China
DPR Korea
Viet Nam
vial 0.42-5.12/g 2.56/g
Flakes 3 0% China vial 3.00/g 3.00/g
Ointment 1 - Viet Nam vial 1.48/vial 1.48/vial
Bear gall powder from DPR Korea
© M. Silverberg/TRAFFIC Southeast Asia.
44Pills, Powders, Vials and Flakes: the bear bile trade in Asia

observed in TM shops were said to be of domestic origin. All raw bile was reportedly from farmed bears in Viet Nam
with one exception; where a shop sold bile alleged to be from bears in DPR Korea. This product cost considerably more at
USD11.79 per vial compared to an average of USD4.19 per vial for Vietnamese bile. Powdered bile came from domestic
and international sources in China and DPR Korea. Prices for Chinese powder were similar to those for Vietnamese
powder; however the DPR Korean powder was signicantly more expensive at USD20.50 per vial. In previous surveys;
Animals Asia found Chinese bear bile from Sichuan to be widely available in TM shops in Hanoi (Jill Robinson, Animals
Asia, in litt. to TRAFFIC Southeast Asia, April 2011).
Gall bladders observed for sale were reported to be primarily from Lao PDR and Russia, a few from Viet Nam and one
from DPR Korea. Prices varied dramatically for gall bladder based on alleged origin. The more expensive products were
from Russia at USD18 per gramme and from Lao PDR, costing between USD9 to USD18.40 per gramme. Shop owners
reported the price range for gall bladders sourced from Lao PDR related to whether these came from captive-bred or wild-
caught bears. Gall bladders from DPR Korea were surprisingly less expensive at USD9.40 per gramme, while the least
expensive was domestic gall bladder at USD4 per gramme. A wide price range existed between the two shops selling
whole domestic gall bladders from USD128.20 to USD615 however it is difcult to conclusively say why this is. It is
possible that the less expensive gall bladders were fakes.
In a recent survey conducted by ENV, 22% of people surveyed in Viet Nam stated that they have used bear bile products
with the highest concentration of users being in Hanoi (Vu, 2010). Respondents from this study primarily used bear bile
to treat specic health related illness, while others also stated they used bile for overall general health and entertainment
purposes (Vu, 2010).
Farm surveys
Starting in the 1990s, the bear bile industry steadily
increased in size, corresponding to an improved economy
and higher living standards (Vu, 2010). Limiting
controls were introduced in 2006 when bear bile trade
was banned and the government implemented a micro-
chipping scheme to register captive bears. This process
was intended to limit wild-sourced bears from entering
the bear farm trade and as registered bears died, bear
farms would be slowly phased out.
Overall, micro-chipping in tandem with increased law
enforcement efforts have led to signicant reductions
in the numbers of farmed bears in Viet Nam. However
farms apparently still illegally house high proportions of
un-chipped bears among micro-chipped bears to maintain
bile extraction. A recent report states that authorities have been known to allow some farmers to register and keep illegal
bears rather than conscate them in accordance with the law (Vu, 2010). This may be due to a broad interpretation of the
current laws as to what constitutes the ‘possession’ or ‘keeping’ of bears.
Despite tremendous efforts by the Vietnam Bear Task Force (which includes Animals Asia, ENV, Free the Bears, Wildlife
at Risk (WAR) and WSPA) to increase public awareness and to work with law enforcement; bear farming and bear bile
trade has yet to be effectively controlled. The total number of bears on farms in Viet Nam is estimated to be less than 3000
according to the latest gures from the National Forest Protection Department.
Bear farm surveys were carried out in Viet Nam from September to October 2010. Due to time constraints and the large
number of bear farms in the country, only around 22% of the estimated total of bears on farms were counted. Overall a
minimum total of 667 bears were observed on 34 farms, 99% of which were Asiatic Black Bears. Eleven of the 34 farms
Bear farm near Ha Long Bay, Viet Nam
© M. Silverberg/TRAFFIC Southeast Asia
45 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

visited stated that bile produced was for local consumption. Fourteen farms told surveyors they extracted bile using the
ultrasound method and sold bile from USD0.77-8.16 per 1cm3 vial.
Bear farms in Viet Nam are not typically large scale commercial enterprises such as those located in China, however, this
survey specically targeted the larger bear farms thought to provide for the foreign tourist demand for bile in Hanoi and
Ho Chi Minh City.
The larger farms in Viet Nam are known to openly sell
bear bile to Korean tourists (ENV 2008; ENV 2010).
Two of the farms surveyed, housing over 65 bears, were
Korean-managed. Investigations by Korean TV (KBS)
and ENV found a high density of illegal bear farming
in the area around Ha Long Bay. Recent surveys of this
area observed more than 189 bears on four farms, three
of which were open to the public. In addition, signage at
one of the facilities was in Korean and English, suggesting
that this facility catered to foreign customers. Monitoring
conducted by Animals Asia in the Ha Long Bay area
from September 1-5 2010, found that over 600 foreign
tourists visited one of the largest bear farms in the area,
the majority being Korean. In addition to farms around Ha
Long Bay, farms in Quang Ninh sold bile; openly targeting
Korean tour groups. As of March 2011, the Viet Nam National Administration of Tourism (VNAT) has called on all
provincial Departments of Sports, Culture and Tourism to prohibit all travel companies that organize tours to take tourists
to bear farms where bears are illegally kept and bear bile is extracted. In the case of serious violations VNAT will consider
withdrawing the company’s International Travel Business Licence (WSPA, 2011).
In Phuc Tho district in Ha Noi, bear farmers openly advertised and sold bear bile. In 16 farms visited with ENV, a total
of 149 bears were observed. At one farm, juveniles and a cub were observed, their presence clearly violating the ban on
new bears entering trade. The Wildlife Crime Unit of ENV notied authorities of this specic case but the cub had been
removed from the premises by the time ofcials inspected the site (Vu, 2010). According to the Wildlife Crime Unit, 26
live bear cubs and six adult bears have been seized in Viet Nam since 2007. The prevalence of cubs and bears entering
the farmed trade reiterates concerns about the potential amount of wild-sourced bears on farms in Viet Nam. From 2005-
2011, ENV has recorded a total of 807 bear-related crimes including: advertising, hunting, possession, trade operations,
smuggling and selling. According to ENV, since the 2005 ban on new bears entering trade; a total of 239 potentially
illegal bears, comprising 66 specic cases, have been documented. Since 2007, 31 live cubs have been conscated in
trade, the majority of which were known to be sourced from Lao PDR. In addition, investigations of 52 farms in Nghe An
in November 2010 discovered a number of potentially illegal bears. ENV is currently working with provincial authorities
to determine the legality of the bears at these sites. TRAFFIC surveys from 2010 and previous research by ENV and other
NGOs indicates the domestic illegal trade of bear bile products in Viet Nam is not only ourishing, but has a signicant
illegal cross-border component as many bile products are purchased by primarily Korean tourists and carried across
borders (ENV, 2008; ENV 2010).
Today Viet Nam plays a signicant dual role as both a producer and consumer of bear bile products. Information collected
in recent surveys, as well as previous research by ENV suggests that there is an illegal cross-border trade in bear bile
products out of Viet Nam. Although bear bile medicine is illegal, domestic consumption is high and some products are
cross-border-sourced.
Bear cub at a farm in Hanoi
© M. Silverberg/TRAFFIC Southeast Asia
46Pills, Powders, Vials and Flakes: the bear bile trade in Asia

GENERAL DISCUSSION
Bear bile products
There was a signicant degree of variation in the types of products available in the study countries/territories (Figure 16).
Some surveys found little variety; for example in Myanmar only gall bladders were observed, while in Taiwan the only
product found was powder. Locations, such as China, Japan, Malaysia and Viet Nam, had a greater variety of products for
sale. These regional differences may be attributed to the dynamics of a particular country/territory’s consumer demand,
frequency of medicinal bear bile use and/or role as a source/exporter.
Figure 16
Percentage availability of bear bile products found in surveyed TM outlets that reportedly sold bear
bile products for each country/territory
The products most frequently observed across the study countries/territories were gall bladders and pills, both of which
were observed in over half of the countries/territories surveyed. Average price per product for each country/territory were
compared for gall bladder (whole and by the gramme) and pills to describe current economic trends in the bear bile trade
and establish a context for the trade activity observed in the region.
Bear gall bladder
Gall bladders (claimed to be from bears by TM outlet staff) were the most commonly seen product, present in 11 of the
13 countries/territories where bear bile products were found. It should be noted that all gall bladders were believed to be
real (not fake) and from bears if the seller asserted thus; therefore there is some margin for error regarding identication
which could not be amended without proper forensic analysis. In addition to Myanmar where they were the only product
seen in market surveys (other forms were seen on farms), the Republic of Korea had a signicantly high proportion as
well. Gall bladders were sold by the gramme or in whole form. There was often a broad price range for the product
within each country/territory as well as between countries/territories. Comparing average prices between the countries/
territories illustrates how gall bladder can either be relatively inexpensive or a highly priced commodity depending on
the country/territory. Low prices also point to there being a substantial amount of fake gall bladders from pigs and other
animals for sale in markets and TM shops.
47 Pills, Powders, Vials and Flakes: the bear bile trade in Asia
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Cambodia
mainland China
Hong Kong SAR
Taiwan
Japan
Rep. of Korea
Lao PDR
Malaysia
Myanmar
Singapore
Thailand
Viet Nam
Gallbladder
Bile
Powder
Pills
Flakes
Other

Gall bladder: prices per whole
Whole gall bladders were observed for sale in Cambodia, Hong Kong SAR, the Republic of Korea, Malaysia, Myanmar,
Thailand and Viet Nam (Figure 17). Prices varied signicantly from less than USD100 to USD2000.
Figure 17
Average price (USD) per whole gall bladder in each country/territory where whole gall bladders were
observed for sale.
Whole gall bladders were least expensive in Myanmar. Prices may have been lowest here because it was the only product
for sale and also widely available. Prices were also relatively low in Thailand, where one shop owner said gall bladders
were wild-sourced and supplied by a Thai agent. In Malaysia, gall bladders were primarily seen in the east Malaysian
states of Sabah and Sarawak where many shop owners described their stock as several years old. This may indicate a low
turnover, which may also explain the lower prices seen.
Prices for whole gall bladders exceeded USD600 in Cambodia. The product was found in two TM shops, both of which
claimed that their stock had been wild-sourced from Cambodia; a possible explanation for the high price. Whole gall
bladders were exorbitantly more expensive in the Republic of Korea and Hong Kong SAR where prices reached up to
USD2000. The high prices in both places could be due to the fact that most of the whole gall bladders for sale were
foreign-sourced, there is limited supply, persistent demand, and a comparatively wealthy market base willing to pay high
prices. In Hong Kong SAR, prices have appeared to be steadily increasing. This may be due to the fact previous surveys
on gall bladder prices in Hong Kong were conducted over 15 years ago when regulation/enforcement may have had an
impact at the time which may not have been sustained since then (Mills and Servheen, 1994; Mills et al., 1995).
Gall bladder: prices per gramme
Gall bladders were observed for sale by the gramme in China, Hong Kong SAR, Japan, the Republic of Korea, Malaysia,
Thailand and Viet Nam (Figure 18). As with gall bladders sold in whole form, there were signicant price variations
between countries/territories.
$371.60
$116.09
$51.11
$150.63
$1,856.00
$2,000.00
$625.00
$0.00
$500.00
$1,000.00
$1,500.00
$2,000.00
Viet Nam
Thailand
Myanmar
Malaysia
Rep. of Korea
Hong Kong SAR
Cambodia
48Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Figure 18
Average price (USD) per gramme of gall bladder in each country/territory where gramme of gall bladder
were observed for sale
Survey results indicated gall bladder per gramme cost the least in Thailand. However this was from a single TM shop
and it is possible the product was not authentic; as gall bladders from other animals, such as pigs, are sometimes sold as
authentic bear products (Mills et al., 1995; Shepherd and Nijman, 2008). Apart from Thailand, prices per gramme were
lowest in China, Malaysia and Viet Nam. This may be because gall bladders are more readily available in these countries.
Similar to whole gall bladders, gall bladder sold by the gramme was considerably more expensive in Hong Kong SAR
and the Republic of Korea. Japan had the highest prices; about double those seen in any other country/territory surveyed.
In Japan, two of the four TM shops selling bear gall bladders claimed their stock was of Japanese origin and that prices
had been high for several years. Previous surveys documented by Ishihara (2005) found an average price of USD55 per
gramme, indicating prices have doubled over the past ve years since then.
Bear bile pills
Bear bile pills were sold in many different forms and packages. There was a broad price range for pills within each
country/territory relative to the pill’s composition and the volume purchased (Figure 19).
Figure 19
Average price (USD) per pill in each country/territory where pills were observed for sale.
$11.72
$0.11
$5.02
$55.38
$109.70
$44.50
$2.37
$0.00
$20.00
$40.00
$60.00
$80.00
$100.00
$120.00
Viet Nam
Thailand
Malaysia
Rep. of Korea
Japan
Hong Kong SAR
mainland China
$3.83
$1.58
$0.38
$1.50
$3.43
$0.54
$1.14
$0.00 $0.50 $1.00 $1.50 $2.00 $2.50 $3.00 $3.50 $4.00 $4.50
Thailand
Singapore
Malaysia
Lao PDR
Japan
Hong Kong SAR
mainland China
49 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

The price of pills may be lower in Malaysia because they are sometimes mixed with other products, such as pearl for
example. In addition, nearly thirty percent of the pills observed were manufactured domestically in Malaysia, which
may be another contributing factor to their low cost. TM shops in Hong Kong SAR also sold relatively inexpensive
pills, possibly due to there being a small proportion of bile amongst other ingredients. As bear bile is a high-value TM
ingredient, the quantity of bear bile within a product directly inuences the price. It is possible the pills available in both
Malaysia and Hong Kong SAR were either not derived from authentic bear bile or were a UDCA substitute being sold as
‘bear bile’.
Overall, prices for bear bile products varied signicantly across the region. Across the price data, products in Malaysia
were consistently less expensive. Products in Japan and the Republic of Korea were comparatively much more expensive.
Prices in China were consistently low to mid-range which may be attributed to the availability, high frequency of use and
legality of these products.
Bear bile product origins
Different types of bear bile products were found in surveyed TM outlets in 12 of the 13 countries/territories; with the
exception of Macao SAR (Figure 16). The relative percentage of shops selling bear bile products was determined to
compare the availability of bear bile products across the study countries/territories (Figure 20). It should be noted that
the legality of bear bile trade in a country/territory may be related to the percentage of TM outlets found there that sold
bear bile products.
Figure 20
Percentages of TM outlets that sold bear bile products;
(*) surveys conducted in wildlife markets
24%
61%
65%
41%
31%
43%
16%
58%
71%
6%
42%
65%
0%
20%
40%
60%
80%
100%
Cambodia
mainland China
Hong Kong SAR
Taiwan
Japan
Rep. of Korea
Lao PDR
Malaysia
Myanmar*
Singapore
Thailand
Viet Nam
Country/
Territory
#
Outlets
# with
Bear Bile
Cambodia 17 4
China 194 119
Hong Kong 20 13
Japan 67 21
Lao PDR 37 6
Macao 10 0
Malaysia 212 124
Myanmar 42 30
Singapore 50 3
Rep. of Korea 61 26
Taiwan 64 26
Thailand 78 33
Viet Nam 31 20
Table 20
Total number of TM outlets sur-
veyed and number of outlets where
bear bile products were found per
country/territory
50Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Products were most prevalent in mainland China, Hong Kong SAR, Malaysia, Myanmar and Viet Nam where they were
seen at over 50% of TM shops surveyed. Products were slightly less prevalent but still readily available at over 30% of
TM shops in Japan, the Republic of Korea, Taiwan and Thailand. Products were less easy to nd in Cambodia (24%),
Lao PDR (16%) and Singapore (6%).
Bear bile products, specically gall bladders as described above, were most available in Myanmar (71%) at Tachilek and
Mong La markets near the Chinese and Thai borders. These markets sell many species in large quantities, nearly all of
which are sourced from the wild. Previous survey work in the area has documented that buyers move items from one
country to another with little to no problem (Shepherd, 2006). These data appear to support previous ndings that indicate
the existence of a thriving and illegal trans-border trade in Myanmar (Shepherd and Nijman, 2007; Shepherd and Nijman,
2008).
Products were seen the second-most often in Hong Kong SAR and Viet Nam (65%). Despite being illegal, bear bile
products are widely available in Viet Nam where bear bile use is often not viewed negatively because it is perceived to
have a medicinal value, rooted in tradition (Vu, 2010). In Hong Kong SAR, product prevalence may have increased in
recent years. Surveys in 1991 found a 95% product prevalence, however this dropped to 6% four years later following
a large government seizure and the implementation of a licensing and registration scheme (Mills et al., 1995),. It would
appear that since this low point of availability, products have made their way back into the Hong Kong SAR market (Mills
et al., 1995). Unsurprisingly, bear bile was quite prevalent in each of the provinces surveyed in China as well (61%);
probably because bear farms and bear bile products are legal. These results are comparable to previous surveys from 1995
where products were consistently observed throughout the country (Mills et al., 1995).
In Malaysia more than half (58%) of the TM shops surveyed sold bear bile. These results would indicate the existence of
signicant consumer demand, and is comparable to the ndings of previous surveys conducted in 1991 where nine out of
13 TM shops carried products. Malaysia’s population is 23.7% ethnically Chinese (CIA, 2011) and there is an established
TM trade in the country. The poaching of wildlife; including bears, to supply TM consumers and the exotic meat trades
in Malaysia has been previously documented (Shepherd and Shepherd, 2010).
Compared to previous research, current data show some signicant changes in product availability in Asia, especially in
Singapore and Macao SAR where few to no bear bile products were observed. Surveys in Singapore in 2001 found 75%
of shops sold products, meaning that if these results are indicative of overall market trends, there has been a signicant
reduction in availability (Govind and Ho, 2001). Similarly in 1995, 79% of shops surveyed in Macao SAR had bear bile
(Mills et al., 1995), however recent surveys did not nd the product available.
Domestic vs. cross-border origin
There were signicant differences between the countries/territories in the percentage of products which were domestically
sourced versus those claimed to be sourced from cross-border origins (Figure 21). In Cambodia, Hong Kong SAR,
the Republic of Korea, Lao PDR, Malaysia, Myanmar, Singapore, Taiwan and Thailand; 50% or more of the products
surveyed originated in another country/territory. Products found in China and Japan were mostly domestic with 22% or
less reportedly coming from a cross-border source.
51 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Figure 21
Relative proportions of domestically or cross-border-sourced products in TM shops, where product
origin was stated. Product origin was unclear in some cases and is not represented in this gure. (*)
surveys were conducted in known wildlife markets, not TM shops
Data on product origins were more available in some countries/territorites
than others; it was most noticeably under-reported from surveys conducted
in Japan where the data were not forthcoming from TM shop owners (Table
21). In instances where product origin was stated, almost all (99%) of the
products found in China were domestic. This is likely to be because China
is able to produce large amounts of bile from legal, commercialized bear
farms that operate within the country. These farms are thought to exceed
the levels of national annual consumption (Robinson, 2009). Where origin
was stated, the majority of bear bile in Taiwan (96%) was reportedly cross-
border sourced from mainland China.
Where product origin was stated in Japan, bear bile was also largely do-
mestic (78%), and products are known to enter the market in several ways;
by legal and illegal hunting, wildlife control actions and possibly bear
parks. Previous research from 1997 indicates that some products made by
pharmaceutical companies in Japan used bile sourced from China, Canada,
Russia and Nepal (Ishihara, 2005). This is worth noting as products that
may be made in Japan and therefore thought to be domestic, may in fact
contain bile from outside Japan. This scenario may be applicable to other
countries/territories as well.
A majority of the study countries/territories had cross-border-sourced bear bile. One hundred percent of products with
stated origins in Hong Kong SAR were purported to be from Japan, however this is surprising given Hong Kong SAR’s
proximity and relationship with mainland China, where large amounts of bear bile are produced. Similarly, surveys found
100% of products from Lao PDR were cross-border sourced. Previous publications have described Lao PDR as a source
country for wild bears, however no domestic products were recently observed even though bear farms are present, perhaps
indicating that products from Lao PDR are all exported to other countries (Robinson et al., 2007; MacGregor, 2010)
Country/Territory
% of TM
outlets selling
products of
unclear origin
Cambodia 0%
mainland China 13%
Hong Kong SAR 30%
Taiwan 4%
Japan 71%
Republic of Korea 15%
Lao PDR 0%
Malaysia 8%
Myanmar 0%
Singapore 0%
Thailand 3%
Viet Nam 0%
Table 21
Percent of surveyed TM outlets
selling bear bile products of unclear
origin
52Pills, Powders, Vials and Flakes: the bear bile trade in Asia
50%
1%
100%
92%
22%
93%
100%
66% 67% 67%
96%
40%
0%
20%
40%
60%
80%
100%
Cambodia
mainland China
Hong Kong SAR
Taiwan
Japan
Rep. of Korea
Lao PDR
Malaysia
Myanmar*
Singapore
Thailand
Viet Nam
Domestic
Cross-border

In addition to Lao PDR, Myanmar and Thailand both had large amounts of cross-border products (where product origin
was stated), possibly because of the close proximity of these three countries to one another and the existence of well es-
tablished trade routes and markets that connect individual merchants and trading companies.
Where origin was reported, TM shops in Malaysia had a large proportion (66%) of stock from outside Malaysia. There
were signicant differences between Peninsular Malaysia and the east Malaysian States of Sabah and Sarawak. The
percentage of cross-border-sourced products found in Sabah and Sarawak was only 13%; as a majority of the products
observed were domestic Sun Bear gall bladders. TM shops in Peninsular Malaysia, however, had a much larger propor-
tion (57%) of cross-border-sourced products for sale.
Despite the presence of bear farms in the Republic of Korea, 93% of the products observed with a stated origin were
cross-border-sourced from China and Russia. This may be because a higher value seemed to be associated with foreign,
wild-sourced products. In the Republic of Korea, gall bladder from China (averaging USD29.60 per gramme) cost less
than that from Russia (USD65.62 per gramme), possibly attributed to gall bladder being more readily available from
China and/or the likelihood that gall bladder sourced from Russia was wild-caught and therefore deemed to be of a higher
quality.
Cross-border-sourced products
Cross-border product origin was analysed for the countries/territories where TM shops maintained stocks of 50% or
greater cross-border origin (Figure 22).
Figure 22
Relative percentages of purported product origin for market locations where TM stock was 50% or
more cross-border-sourced.
A signicant amount of cross-border-sourced products came from mainland China. This was particularly true for Cam-
bodia, Lao PDR, Malaysia, Singapore and Thailand where 70% to 100% of the products for sale were reported to be from
mainland China. In the Republic of Korea, a majority of cross-border products (60%) came from Russia, where bears
were said to be wild-sourced. One hundred percent of the cross-border-sourced gall bladders found in Myanmar were
stated to be from Lao PDR where sourcing from wild bear populations is known to occur. In Malaysia, a small percentage
of products (6%) were reportedly from Indonesia. In addition, less than 5% of products were said to be from Thailand,
Viet Nam, Nepal and Singapore. Thailand also had small percentages of bear bile from Taiwan.
17%
60%
11%
100%
11%
100%
7%
100%
40%
83% 88%
100% 96%
74%
0%
20%
40%
60%
80%
100%
Cambodia
Hong Kong SAR
Rep. of Korea
Lao PDR
Malaysia
Myanmar
Singapore
Taiwan
Thailand
mainland China
Indonesia
Japan
Lao PDR
Myanmar
Russia
Viet Nam
Other (<5%)
53 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Overall, these data re-afrm previous research conducted on the trade in bear bile. These studies indicate that bear bile
products are widely available in many Asian countries and that a majority of these manufactured products originate from
mainland China, despite such trade being in complete violation of CITES trade regulations (Mills et al., 1995; Watkins
and Hseih, 2000; Yi, 2000; Phillips and Wilson, 2002).
Legalities of bear bile trade
Depending on national legislation, domestic bear bile trade can be legal (such as in China and Japan) or illegal (Cambo-
dia, Malaysia, Myanmar, Singapore and Thailand). Regardless of the legality of trade within a country, all cross-border
trade without proper import/export permits is an infraction of CITES trade regulation agreements. All of the countries/
territories covered in this report are Party to, or subject to CITES.
With the exception of Macao SAR, all of the countries/territories surveyed in this report had an availability of bear bile
products with the stated origin of manufacture coming from outside political jurisdictions. A model of illegal cross-border
trade is represented in Figure 23 where each arrow represents both illegal export (arrow end) and illegal import (arrow
point).
Malaysia imported bear bile from the greatest number of countries: China, Indonesia, Singapore, Thailand and Viet Nam.
Thailand and Viet Nam also had imported bear bile from at least four different countries/territories (Figure 23). China
imported the least bear bile, but Chinese branded products were traded without CITES documents to most countries/ter-
ritories: Cambodia, Lao PDR, Japan, the Republic of Korea, Malaysia, Singapore, Taiwan, Thailand and Viet Nam. None
of these exports are legal under CITES protocols. No imported products from Cambodia, Hong Kong SAR, the Republic
of Korea and Malaysia were observed in other countries.
Another interesting aspect of this analysis is the depiction of Russia as a signicant source country for China, the largest
exporter, as well as for the Republic of Korea and Viet Nam, two signicant consumer countries. The hunting and trade
of Brown Bears is legal in Russia; however since 1992 the legal export/import of bears and bear products has required
CITES permits. From 2001, the UNEP-WCMC CITES trade database records Brown Bear gall and/or gall bladder(s)
were sent to Hong Kong (6 records; over 1223.158 kg), Republic of Korea (4 records; 15.963 kg) and Japan (1 record;
0.048 kg).
In a 1998 study, dealers were reported to come directly from China, Japan and Viet Nam to buy gall bladders in Russia
and from there smuggle them out of the country (Chestin, 1998). Another study noted that demand and trade incentive
during the mid-1990s was so high that there was a signicant amount of counterfeit bear gall bladder in trade, including
some from such nefarious sources as human morgues (Chestin and Poyarkov, 1995). The current extent of trade in bear
bile products and the proportion which involves counterfeit items is unknown.
54Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Figure 23
Illegal cross-border trade connections based on purported product origins in TRAFFIC surveys of TM
outlets, 2010/20111.
Map designed by Olivier S. Caillabet.
1Although not depicted in this map, previous research has indicated that trade occurs from Myanmar to China as well as
from Russia to Japan (Chestin, 1998; Shepherd and Nijman, 2008)
Bear farming
Bear farms are known to occur in China, Lao PDR, Myanmar, the Republic of Korea and Viet Nam. There is some
argument that bear farms help conserve wild bears by alleviating hunting pressures (Yi, 2000; Haikui and Zhi, 2007).
However, this has not been proven conclusively, and there is evidence that farming may in fact be detrimental to the
conservation of wild populations. Bears are thought to be consistently sourced from the wild to re-stock farms because
of high mortality rates and the absence of captive breeding; as well as because prices for bear gall bladder or bile from
wild-caught bears remains higher than for farmed products.
55 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Previous research, as well as the information presented in this report, indicates there is a signicant preference for wild
bear bile products (Robinson, 2009). If this preference remains high, pressures on wild populations will remain high,
regardless of the quantity of farmed bile or UCDA alternatives available. Farms themselves may put direct pressure on
wild populations. Many farms reported high mortality rates. As bears die off, stocks need to be replenished in order to
maintain protable levels of bile output. Although captive breeding may occur on some farms, it is likely that the hus-
bandry conditions and practices in many are not conducive to the successful production and rearing of cubs. Farmed bears
are often kept as captive individuals, rather than in groups, with little or no space provided for animals to socialise or mate
in other areas. In places where captive breeding does not occur, it is likely that farms re-stock from the wild. During the
data collection for this report, farms in Lao PDR and Myanmar conrmed to TRAFFIC surveyors that they sourced bears
from the wild. Only four of the farms surveyed in Viet Nam stated they had captive breeding programs.
The non-existent or potentially negative impact of ‘farming’ on wild populations has been documented previously for
species other than bears. A case study on the use of porcupine farming in Viet Nam as a conservation measure for wild
populations found the practice had a negative effect on wild porcupine populations (Brooks et al., 2010). Wild-caught
porcupines were consistently preferred over the farmed alternative and the overall increase in availability created a com-
modity demand for the species.
Recent surveys conducted by TRAFFIC and others indicate the presence of a signicant number of bear farms, some of
which operate and sell bile illegally. In Viet Nam, many farms continue to sell bear bile to local and foreign buyers despite
such commerce being illegal since 2005. Information was obtained on legal bear farms which maintain substantial num-
bers of bears in the Republic of Korea, however no products from the Republic of Korea were observed in other countries/
territories. It is possible that recent survey results are not indicative of the current situation in that country. However,
if they are, then these results raise questions about why bear farms still exist in the Republic of Korea. Presence of bear
farms was positively correlated with high product prevalence in TM shops and signicant amounts of illegally-sourced
bile. All countries with bear farms, with the exception of the Republic of Korea, were found to play dual roles as both
consumer and producer countries/territories in the bear bile trade. This indicates that bear farms have little to no effect in
decreasing the volume of the bear bile trade or the movement of illegal products; and in fact may be used as a cover for
illegal cross-border trade.
Enforcement and seizure data
Improving enforcement in order to combat the illegal trade of bear bile products in Asia is critical. Even with good
national legislation in place, many factors such as corruption, poor legislation and ineffective enforcement often allow
illegal wildlife trade to occur. Despite the potential effects of these factors, enforcement action specically involving
gall bladder and bear bile product seizures has occurred in many of the study areas covered in this report. Due to the
limited information available on seizures from 2000 to 2010, (totalling 506), it was not possible to draw rm conclusions
about trade levels and country/territory-specic enforcement efforts. However, some ndings do reect enforcement and
seizure trends.
Seizure sizes varied dramatically, ranging from large, such as the 16 gall bladders seized in Ba Dinh district, Viet Nam
in 2009 (Anon., 2009), to small, such as the 33 capsules of bear bile seized in the UK en route from China in 2000 (HM
Customs and Exercise CITES Seizures Report, 2000). From the limited seizure data available, it is clear that signicant
amounts of unspecied bear bile products in all forms have been seized since 2000 (Table 21). Although these data are
likely to represent only a small proportion of total trade, they clearly illustrate a high volume of bear bile trade both from
and through Asia.
56Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Of the total seizure cases, 81% (409 of 506) had a stated place of origin. Of those with a stated origin, the estimated
majority (98%) were from China. A side by side comparison of the total information gathered, versus what was available
from the UNEP-WCMC CITES trade database is given to 1) show where any overlap in information gathering may have
occurred and 2) highlight that the UNEP-WCMC data are often incomplete. This is illustrated particularly in the case
of Japan (Table 22). There was a substantially larger amount of seizure data available for Japan as the trade in bear gall
bladder was the subject of a recent TRAFFIC East Asia report (Ishihara, 2005). The signicantly larger gure for this
country, compared to the other countries, reects a more thorough documentation of seizures up to 2004 in Japan. It is
likely that numbers of seizures reported by other countries are under-reported or undocumented. Table 22 should be seen
as an indication of seizure levels but also highlights the incompleteness of seizure data collection and reporting, especially
by the Parties to the Secretariat for the UNEP-WCMC CITES trade database.
Seized item Quantity
(inc. WCMC)
Whole gall bladder 143 (9)+
Gall bladder (gram) 4456 (40)+
Bile (gram) 7044 (1870)+
Powder (gram) 3812+
Capsules 122+
Unspecied products 10 100+
Table 22
Bear bile gall bladders and bile products
seized from 2000 to 2010
Amount in () denotes stated amounts in the
UNEP-WCMC CITES trade database
Whole gall bladder and pills purported to be from bears
© C. Yeong/TRAFFIC Southeast Asia
57 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Table 23
Asiatic Black Bear, Sun Bear and Brown Bear seizures by country/territory from 2000 to 2010
It is important to note that, although beyond the scope of this research, the trade in bears, their parts and derivatives ex-
tends far beyond the trade in bear bile. Illegal trade in bear parts and derivatives other than gall and bile is common in
Asia and known to occur on a large scale (Mills and Servheen, 1991; Shepherd and Nijman, 2008; Shepherd and Shep-
herd, 2010). For example in June 2009, 25 hind legs and 22 paws from Sun Bears, presumably for the wild meat trade,
were seized in Kuantan, Malaysia (Shepherd and Shepherd, 2010). In Cambodia from 2001 to 2010, 108 live bears, seven
dead bears and 23 skins were seized (Wildlife Alliance, 2011).
In addition to examining information on reported seizures in the UNEP-WCMC CITES trade database, TRAFFIC exam-
ined all bear trade reported regardless of its stated purpose, source and types of specimens and units. In these records
there were no recorded exports for Macao SAR, South Korea or Taiwan. Additionally, there were no recorded imports for
Cambodia, Macao SAR, Malaysia, Myanmar, South Korea and Taiwan. Trade records for all three species from 2000 to
2009 totalled a wild-sourced sum of 98 kg of gall and 1240 kg of gall bladders, all from the Asiatic Black Bear and 72 live
bears (49 Asiatic Black Bear, 18 Brown Bear, ve Sun Bear). It is important to emphasize that these totals are miniscule
compared to the total trade of bear bile products and bear derivatives.
Country/Territory
Total # of
In-Country
Seizures
Total # of
WCMC
Reported
Seizures
# of Seizures
Where Products
Originated From
# Country-Origin
Information From
WCMC
Cambodia 2 - - -
China 2 - 4013-
India 1 - 1 -
Germany 1 1 - -
Hong Kong SAR 13 - 1 -
Japan2403 - - -
Lao PDR - - 1 1
Malaysia 11- - -
Myanmar 1 - 2 -
New Zealand 3 3 - -
Singapore 38 - - -
Taiwan 7 - - -
Thailand - - 2 -
United Kingdom 15 - - -
United States 11 10 - -
Viet Nam 8 - 1 -
1 Malaysia’s single seizure entry was a campaign where a total of 43 gall bladders from several shops were
seized.
2 Seizure data for Japan was much more complete as an extensive report compiled in 2004 supplemented
other collected seizure data (Ishihara, 2005).
3 Ishihara (2005) states 608 of 647 (94%) seizures 1995-2004, were of products that originated in China.
As this report focuses on seizures since 2000, the same percentage (94%) has been applied to the total
since 2000 (403) to generate an approximate number (379).
58Pills, Powders, Vials and Flakes: the bear bile trade in Asia

CONCLUSION
Illegal harvesting and trade of wild bears, their parts and derivatives, continues across Asia on a large scale, often openly
in violation of national laws and CITES protocols. Many of the countries/territories were observed to play a signicant
role as consumer markets in the bear bile trade. Availability of products was observed to be highest in Myanmar, Hong
Kong SAR, Viet Nam and China; where more than 60% of shops sold bear bile products. Consumer demand was also
observed to be high in a large percentage of shops in Malaysia, Republic of Korea, Thailand and Taiwan where 40%
or more of shops surveyed sold bear bile products. Although shops were also observed to sell bear bile products in
Cambodia, Japan, Lao PDR, and Singapore; consumer demand appears to be less as bear bile was observed less frequently
in comparison to that found in other countries/territories.
Many of the surveyed countries/territories also produced bear bile. China appeared to be the largest producer, as seven
countries/territories were observed selling signicant amounts of products purported to originate from China. As
Chinese products are widely available, it would appear bear products are being smuggled despite regulatory and law
enforcement efforts. In Lao PDR, Myanmar and Thailand, survey data indicated the existence of signicant cross-border
trade. TRAFFIC survey data show that outside Viet Nam, products of purported Vietnamese origin were only observed
in Malaysia. Nonetheless, it should be noted that Vietnamese products have been observed in other countries during
previous surveys conducted by Animals Asia (Jill Robinson, Animals Asia, in litt. to TRAFFIC Southeast Asia, April
2011). Although this current survey results do not conrm Viet Nam as a major producer of bear bile products, previous
research indicates that Viet Nam does play a producer role in the international bear bile trade with some domestic TM
outlets specically targeting foreign tourists.
Clearly, CITES Parties are failing to curtail illegal bear bile trade and, ultimately, to protect bears from exploitation. As
all bear species are protected to varying degrees under CITES, there is an obvious need for better follow-through on
CITES commitments. Unbridled illegal trade in bears and bear parts continues to undermine what could be, and should
be, the world’s most powerful tool to regulate cross-border wildlife trade. As the Convention is legally binding, it must
be supported by complementary national laws; CITES Parties are required to have adequate legislation to effectively
implement and enforce CITES regulations. However many countries have yet to follow through on this obligation. The
true value of CITES ultimately rests on the co-operation of the Parties, which is vital to the protection and conservation
of threatened species (Cheung, 1995). Inadequate, or in some cases near total absence of enforcement, allows illegal
harvest and trade to continue as a leading threat to the survival of Asian bears. Ultimately, whether CITES is effective in
eliminating the illicit trade in Appendix I-listed species depends on the will of the Parties to make compliance with the
Convention a priority (Cheung, 1995).
In addition to the implementation and enforcement of CITES to control international trade, enforcement of domestic
laws protecting bears at national levels is absolutely vital. The ndings of this report suggest that national laws are not
being enforced to their full extent and that efforts to close down the illegal trade in bears, bear parts and derivatives
are sorely inadequate. Furthermore, many of the products observed during this study were wild-sourced, and therefore
refute arguments about the efcacy of bear farming practices as a conservation measure to alleviate pressure on wild bear
populations. To address the large scale illegal trade in bear bile products and to aid in bear conservation efforts, TRAFFIC
makes the following recommendations:
59 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

RECOMMENDATIONS
• TM outlets selling illegal bear parts and derivatives need to be penalized or closed down and illegal products
conscated. Individuals caught collecting, selling, buying transporting or keeping illegal bear parts and
derivatives, in violation of national laws or CITES, must be prosecuted. Penalties should be severe enough
to serve as a deterrent to individuals in the future.
• Better enforcement could appropriately be undertaken not only by CITES Authorities, police and Customs
authorities who are already empowered by national government to initiate such efforts, but also by
collaborative inter-governmental efforts, including through the Association of Southeast Asian Nations
Wildlife Enforcement Network (ASEAN-WEN) and the partner members of the International Consortium
on Combating Wildlife Crime (ICCWC – which links the CITES Secretariat, INTERPOL, the United
Nations Ofce on Drugs and Crime, the World Customs Organization and the World Bank).
• Illegal bear farms should be closed down permanently by relevant authorities in each country. Facilities
where bears cannot be immediately removed should be closely monitored by a combination of government,
international and civil society specialists to ensure harvesting of bile does not continue, new bears are not
acquired and bear farms are not a source of illegal trade. Violations should be punished to the full extent
of the law.
• Legal bear farms should be regularly monitored by designated authorities who monitor the wildlife trade to
ensure they are adhering to regulations. Where violations occur; bear farm owners should be punished to
the full extent of the law.
• The CITES Secretariat/Standing Committee and/or individual Parties to CITES should take steps to ensure
that countries abide by the text of the Convention in regards to the international commercial trade in bears,
their parts and derivatives. Findings of this report should be raised by TRAFFIC and the IUCN SSC Bear
Specialist Group at the next meeting of the Conference of the Parties (CoP 16, Bangkok, Thailand, 2013).
• Campaigns by local and international civil society actors in collaboration with relevant government
agencies to tackle illegal consumption of bear bile products should be carried out in all consumer countries.
Campaigns should also focus on raising awareness amongst enforcement agencies so as to increase
motivation and capacity to tackle the illegal trade in bears, their parts and derivatives. Campaigns should
also be carried out in bear range States to raise the prole of bears and the need to protect them. Local
communities should be encouraged not only to protect bears but also to work with enforcement agencies to
take action against bear poachers and traders.
• All countries experiencing illegal wildlife trade should ensure anonymous wildlife crime hotlines are in
place and known to the public. The public should be encouraged to report all instances of illegal hunting
and trade of bears and bear products.
• In the interest of national accountability, TRAFFIC suggests that all cases pertaining to bears be tracked and
reported internationally via a centralized database. Such reporting of seizures, arrests and prosecutions is
done for elephants via the Elephant Trade Information System (ETIS) and moves are afoot to monitor Tiger
cases in a similar fashion. A system to manage and maintain a central database for bear-related seizures
in order to monitor trends and analyse bear trade should take into account the lessons learned from similar
databases established for other species. Information generated from this database should be provided in a
timely manner to relevant enforcement agencies.
60Pills, Powders, Vials and Flakes: the bear bile trade in Asia

Country-specic recommendations
• Current domestic legislation in China should be amended to up-list the Asiatic Black Bear from Category
2 to Category 1, as the species is considered Vulnerable with a globally declining population trend (IUCN,
2011).
• In mainland China, close all unlicensed bear farms as well as those farms which have licences but do not
adhere to current regulations. In addition, farm owners who contravene CITES regulations by illegally
exporting bile should have their bear farm licences revoked and be prosecuted to the fullest extent of the
law.
• As stated in Ishihara (2005), it is recommended that Japanese legislation be amended to include Japanese
domestic bears and bear gall bladders under the Law for the Conservation of Endangered Species of Wild
Fauna and Flora.
• The Republic of Korea should end the practice of bear farming in order to remove any confusion on the
legality of products in the country and to eliminate threats to wild bears.
• In Lao PDR and Myanmar, steps need to be taken to assist both countries to achieve Category 1 CITES
implementing legislation status. In absence of Category 1 status, punitive measures should be taken to
mitigate illegal trade in and from these countries.
• In Lao PDR, the trade of parts and derivatives from second generation captive-bred bears is permitted under
the Wildlife and Aquatic Law (2007) with proper approval. However as bears are protected in the country,
obtaining parent stock from the wild is illegal. As it seems to be highly unlikely that bears are being bred
on farms and in the absence of monitoring systems to accurately determine whether the animals derive
from wild or captive sources; farms should be closed down to avoid abuse of this loophole. In addition,
legislation should be amended to close these loopholes and to more fully protect wildlife.
• In Malaysia, authorities should investigate shops and manufacturers selling and producing both real and
purported bear bile medicines and prosecute them accordingly.
• In Myanmar nes for violation of the Protection of Wild Life and Wild Plants and Conservation of Natural
Areas Law (1994) should be increased to deter poaching and trade.
• In Myanmar, the Asiatic Black Bear should be up-listed to Totally Protected on the list of Wildlife Protected
from the Forest Department.
• Research on the role Russia plays in the bear bile trade should be conducted as the results from these recent
surveys indicate that Russia is an important source of bear gall bladders in China, Republic of Korea and
Viet Nam and the proportion of illegal trade is unknown.
• In Viet Nam, authorities should enforce national legislation; bear farms should be closed down in Viet Nam
to prevent violations of national legislation and CITES commitments as there is evidence that these farms
illegally extract and sell bear bile to local and foreign consumers.
• Legislation in Viet Nam should be amended and claried: 1) to cover the import, export and transit of
species which are CITES-listed but of domestic or unclear origin as these are not included under the current
law, 2) to cover bear cubs born in captivity under the Regulation of Bear Management Decision 95/2008/
QD-BNN (2008), and 3) to clearly dene what constitutes the ‘possession’ or ‘keeping’ of bears.
61 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

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67 Pills, Powders, Vials and Flakes: the bear bile trade in Asia

TRAFFIC, the wildlife trade monitoring network, works to
ensure that trade in wild plants and animals is not a threat to
the conservation of nature.
For further information contact:
The Director
TRAFFIC Southeast Asia
Unit 3-2, 1st Floor
Jalan SS 23/11, Taman SEA
Petaling Jaya, Selangor
Malaysia
Telephone: (603) 7880 3940
Fax: (603) 7882 0171
Email: tsea@po.jaring.my
The Executive Director
TRAFFIC International
219a Huntington Road
Cambridge CB3 0DL
United Kingdom
Telephone: (44) 1223 277427
Fax: (44) 1223 277237
Email: trafc@trafc.org