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Konstanzer Journal für Politik und Verwaltung Vol. 1 No. 1 (Oktober 2011), pp. 52-62
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MONEY or PRIDE?
On the Why and How of Traditional Knowledge Protection
in India and China
Christopher Schulz∗
Abstract. The interest in traditional knowledge (TK) and its importance as a source for inno-
vation in science and medicine have been rising and so have conflicts around it. In this article,
the policies on TK of India and China are reviewed and analysed. While India put emphasis on
preventing the unauthorized use of its TK, China is mainly concerned about integrating its TK
into modern Western science. China’s economy and research facilities are growing at a faster
pace and TK policy is centred on traditional Chinese medicine. In turn, India has a great va-
riety of equally important TK traditions, which are more vulnerable to misappropriation thus
explaining the differences between the two countries’ policies.
Introduction
For many centuries, people in India have been
brushing their teeth with twigs of the neem
tree using its antibacterial properties to pro-
tect their teeth. Neem had also been tradi-
tionally used as a natural pesticide in agricul-
ture on Indian fields. In 1985, however, the
first U.S. patent on a neem-based solution was
granted and since then more than 150 patents
all over the world have followed using Indian
traditional knowledge (TK) as a starting point
for their inventions (Mathur, 2003, p.4473). A
few neem patents were revoked in reaction to
protests of activists and international NGOs,
such as in 2000 when the European Patent Or-
ganisation decided that the use of neem as a
pesticide could not be considered novel (CIPR,
2002, p.76).
The case of the neem tree has been cited
many times to illustrate how Western intel-
lectual property rights (IPRs) can be used by
multinational companies for misappropriating
TK, which usually originates from developing
countries. Moreover, it has caused a lively de-
bate on the appropriate protection of TK in the
media, among activists and NGOs, in the sci-
entific community, and within states and in-
ternational organizations. Without an interna-
tional agreement in place, national rules and
protection systems are the decisive factor when
it comes to the protection of TK (WTO, 2006,
p.5). Focusing on that issue, this article tries
to illuminate why TK protection is in place and
how it is designed. It does so by reviewing the
different national policies concerning TK pro-
tection in two of the most important TK holder
countries, namely India and China. As no com-
parison of the two countries’ policies has been
undertaken yet, this article proceeds in a rather
exploratory way aiming at identifying possi-
ble explanatory factors for national differences.
The author explicitly takes a political science
perspective as the interests and preferences of
∗Christopher Schulz (BA - 4. Semester)
Email: christopher.schulz@uni-konstanz.de
53 Konstanzer Journal für Politik und Verwaltung
those actors involved in the policy-making pro-
cess with respect to strategies of TK protec-
tion have not been systematically addressed so
far.
At first, a brief introduction to the basic terms,
i.e. TK and its protection is given, which is
then followed by a short overview of possi-
ble policy options and the current international
legislation on TK protection. The second part
deals with India’s and China’s approach to
protecting TK. Various factors explaining na-
tional differences are proposed and discussed,
namely economic interests, the unique charac-
teristics of each country’s TK, the ethnic com-
position of each society as well as the pub-
lic opinion and general awareness of the issue
as a whole. In addition, national TK protec-
tion policies are put into a larger context of
China’s and India’s general foreign policy in-
terests.
Characteristics of traditional
knowledge and its protec-
tion
In spite of intensive discussions a generally ac-
cepted definition of TK has not yet been agreed
on (Mugabe et al., 2001, pp.2-3). This is largely
due to the extremely broad use of the term,
which has rather evolved from everyday use
and common sense than from a clearly-defined
scientific concept. TK is usually applied for
any knowledge generated outside the context
of modern Western knowledge and covers a
large amount of distinct subcategories, which
in extreme cases might have little to nothing
in common (Correa, 2001, p.4). TK can in-
volve cultural expressions, ecology, agriculture
or medicine. It can be held by individuals, com-
munities or society as a whole. It might be writ-
ten down or preserved only orally. Some of it is
centuries-old, and some is the result of recent
research (CIPR, 2002, p.75). It is important to
keep this diversity in mind as policies on TK
protection may have different effects according
to its nature, its content, its number of holders,
its accessibility or its age. Having discussed the
complexity of the term traditional knowledge, it
is important to clarify the term protection. The
protection of TK comprises concepts like eq-
uity, preservation, prevention of misappropri-
ation, self-determination and promotion (Cor-
rea, 2002, pp.25-26). Equity refers to the prob-
lem of unequal treatment of TK compared to
modern knowledge by legal institutions. This is
a result of its unclear status (ibid., p.26). Preser-
vation is an important objective for TK, espe-
cially if it is held only orally by small commu-
nities or individuals (ibid., p.30). Prevention of
misappropriation of TK is better known as the
fight against bio-piracy if biological knowledge
is involved. It is the use of TK for economic
reasons without authorization or compensa-
tion of its original holders (ibid., p.36). Self-
determination means that TK holders decide
themselves on the fate of their TK (ibid., p.45)
while protection for promotion refers to encour-
aging the use of TK for commercial exploitation
(ibid., pp.47).
The protection of traditional
knowledge
Defensive or positive protection? – A
typical policy decision dilemma
If a national government needs to decide on
how to protect TK, there is a range of possi-
ble options spanning from defensive to posi-
tive protection of TK – or the choice between
money and pride. While defensive protection in-
volves the prevention of unauthorized use of
TK by actors outside the holder group, positive
protection refers to a term used by the World
Intellectual Property Organisation (WIPO) for
all the means that allow the exclusive use of
TK either by the community itself or exter-
nal actors to promote its application. Gener-
ally, the promotion refers to the commercial-
54 Christopher Schulz
ization of TK (WIPO, n.d.). Indigenous, lo-
cal or rural TK holders usually call for defen-
sive protection as this avoids their TK being ex-
posed to the public domain, which may ben-
efit other members of society, but not them.
This also involves further risks as the original
holders of TK lose their control of it. By con-
trast, companies usually prefer positive protec-
tion because it allows the legal use of TK (van
den Daele et al., 2003, p.6). Thus, in general
national governments can choose any policy
on the continuum between those two extreme
points.
Existing international legal frame-
work
The Convention on Biological Diversity (CBD)
of 1992 is the “most authoritative international
instrument” on the protection of TK” (Ogua-
manam, 2006, p.5). It codifies the interna-
tional consensus that a protection system for
TK is needed and proposes legal mechanisms
towards this objective. For example, it re-
quires “approval and involvement” of the hold-
ers of TK for its use and “equitable sharing
of the benefits arising from the utilization”
of TK. These instruments have to be imple-
mented nationally by its signatories (Löffler,
2001, p.77).
It has to be recognized, however, that its success
is rather limited and its international imple-
mentation is weak (ibid., p.12). It is also worth
noting that the CBD is restricted to traditional
ecological knowledge of indigenous or local
communities and therefore excludes knowl-
edge of other areas, such as traditional cultural
knowledge or traditional medicinal knowledge
(TMK) that is not related to biological resources.
Moreover, codified or common TK being held
by entire countries is not covered by this agree-
ment either.
It is telling for the status quo of TK protection
that a weakly enforced and implemented treaty
covering a limited range of TK is considered
to be the most important international tool to
protect TK. This is why possibilities to protect
TK under the well-established Western Intel-
lectual Property Rights (IPR) system have been
explored intensively. The most relevant inter-
national agreement is the Agreement on Trade
Related Aspects of Intellectual Property Rights
(TRIPS), signed in 1994 by WTO member states.
Under this treaty, signatories are requested to
assure the protection of patents, copyright, new
plant varieties, geographical indications, trade-
marks, and trade secrets, among others (CIPR,
2002, p.3). TK is not mentioned in the treaty, but
in specific cases it can be protected under some
of those IPRs.
Possible policy options to protect tradi-
tional knowledge
Internationally, the easiest and most effective
way to assure TK protection would be adapt-
ing the TRIPS agreement to the special char-
acteristics of TK. This would be in line with
the 2001 Doha Declaration of the WTO Min-
isterial Conference, which calls for examining
TK protection. The TRIPS agreement could
provide a legal framework for an equitable
treatment of TK and modern knowledge (Ger-
vais, 2005, p.163). It has been proposed that
patent applicants of inventions, which are re-
lated to genetic resources, have to disclose its
source and origin. This would create a le-
gal framework that prevented the use of TK
without prior informed consent and allowed
for benefit sharing with TK holders. A sim-
ilar rule would have to apply for any other
invention based on TK (Oguamanam, 2008,
p.518).
55 Konstanzer Journal für Politik und Verwaltung
The protection of traditional
knowledge in India and China
Status quo of traditional knowledge pro-
tection in India
India does have comparatively strong policies
to protect TK and has many times been charac-
terized as an international pioneer in this field.
The country has especially focused on means
to prevent the misappropriation of TK (Cor-
rea, 2002, pp.29-30). Under the Patent Second
Amendment Act of 2002 it is explicitly forbid-
den to file patents on existing TK, while the Bi-
ological Diversity Act 2002 dictates that source
and origin of any biological material used for
an invention have to be disclosed when apply-
ing for a patent. Furthermore, this act stipu-
lates that IPRs on biological resources from In-
dia can only be granted with the approval of the
National Biodiversity Authority (NBA), which,
in turn, should organize benefit sharing with
holders of related TK. This way India complies
with its duties of implementing the CBD. Addi-
tionally, the NBA’s task is to prevent the grant-
ing of any biodiversity-related IPRs to foreign-
ers (WTO, 2000).
In the field of TK protection, India has become
famous for its Traditional Knowledge Digital
Library (TKDL) project. TKDL is a database
containing ancient knowledge on the use of
plants for medicinal and other purposes. This
knowledge, stemming from Ayurvedic, Unani,
Siddha, and Yoga traditions, has been trans-
lated from its original languages such as Hindi,
Urdu, Sanskrit etc. into English, German, Span-
ish, French, and Japanese to make it available
for Western patent examiners in their search
for prior art. A modern TK Resource Clas-
sification system has been developed as well,
which has been linked with the International
Patent Classification system. This system is
used by more than 100 countries and several in-
ternational organizations (Oguamanam, 2008,
pp.499-503). The TKDL has already led to
the withdrawal of about 40 patent applications
while its real impact can hardly be estimated
(TKDL, n.d.).
India’s traditional systems of medicine are not
only wide-spread in the country, but are also
part of the public health system. By con-
trast, regional TK, while being threatened with
extinction, is currently being collected in lo-
cal databases on the initiative of regional gov-
ernments and NGOs (Krishnaswamy, 2009,
p.10).
Status quo of traditional knowledge pro-
tection in China
While it has been stated that China is “highly
concerned about [. . . ] TK protection” (Cui,
2009, p.1), the country proceeds very cautiously
in taking measures towards this objective, as
this issue is being considered a very complex
one. Access and benefit sharing laws concern-
ing the use of genetic resources and related TK
that would put CBD into practice are still being
developed. A draft Patent Act of 2007 refers
to rules for access and benefit sharing while
the Chinese State Environment Protection Ad-
ministration is developing a sui generis system
for this purpose (ibid., pp.1-2). China’s poli-
cies have mainly focused on assuring the in-
tegration of its TK into modern Western sci-
entific knowledge (Oguamanam, 2008, p.505;
Liu, 2008). The only possibilities for TK to be
protected legally are patents or a registration
under the Regulations on Protection of Tradi-
tional Chinese Medicines of 1992. This act aims
at improving the quality of traditional Chinese
medicine (TCM) and promoting research and
development in this field. In sum, these reg-
ulations do only protect TK that has recently
been invented. All other forms of China’s TK
are considered to be in the public domain (Cui,
2009, pp.28-29; p.31). The Chinese State Intel-
lectual Property Office has developed the Tradi-
tional Chinese Medicine Patent Database to aid
patent examiners, which contains about 32,000
formulas which have been patented and are
56 Christopher Schulz
therefore not in the public domain (WIPO-IGC,
2005, p.2).
With respect to preservation of TK, there are
immense differences between the two largest
branches of TK in China. TCM is widespread
and there are many companies producing for
its market of RMB 95.4 billion (EUR 9 billion in
2005). It is also used a lot outside China (Cui,
2009, p.8; p.10). Moreover, doctors specializ-
ing in the field of TCM have to obtain a license
to practice TCM and there are many schools
specialized in the teaching of TCM. The other
branch is traditional indigenous knowledge
(TIK), which has a status comparable to TIK
in other parts of the world. It is usually held
by small communities and is inaccessible due
to its non-codified status (Li Li, 2007, p.127).
For now, TIK is rather marginalized and little is
done for its preservation. However, the Chinese
government has for example sent a research
team to southeast Guizhou, a region with a high
number of ethnic minorities, to conduct a field
study on TIK (Cui, 2009, p.7). The reason for
this might be found in the internationally ris-
ing importance of TK in facilitating the devel-
opment of new pharmaceutical or agricultural
products.
Analyzing the differences be-
tween Indian and Chinese
traditional knowledge protec-
tion
The literature on the protection of TK is domi-
nated by legal scholars. Only in the case of TIK
anthropologists, ethnologists, and sociologists
have contributed to research in this field. How-
ever, there are virtually no publications by po-
litical scientists, and less so for the specific cases
of India and China. Therefore, this article has to
rely on sources which, in the majority of cases,
put a strong emphasis on technical details of le-
gal processes and possible law reforms. The in-
terests and preferences of actors directly or in-
directly involved in the formulation of the laws
of interest have not yet been systematically ex-
plored.
In this section, factors which are likely to af-
fect policy making in the arena of TK protec-
tion and, thus, are hypothesized to contribute
to differences between China and India are pro-
posed. Generally, five distinct dimensions are
differentiated here (see table 1); this systemati-
zation is one of the key contributions of this ar-
ticle. It is the result of a brain storming pro-
cess of the author. This approach contributes
substantially to the debate as existing literature
usually proceeds with a different focus. For ex-
ample, some authors offer in-depth case stud-
ies (see e.g. Cui, 2009; Krishnaswamy, 2009),
while others develop general legal mechanisms
to protect TK (see e.g. Gervais, 2005). In ad-
dition to scientific articles, key documents from
international organisations dealing with intel-
lectual property, such as reports or statements
made at WIPO and WTO, have been consid-
ered.
Economic interests
Why do China’s policies focus on protecting
innovations on TK, rather than on the protec-
tion of TK itself, with the objective of integrat-
ing TK into modern Western science? Most
probably, economic interests are one of the key
drivers. As already mentioned, the domestic
market for TCM is enormous. Similarly, mar-
keting potential of TCM products is also ris-
ing in other countries. Yet, Chinese firms have
to compete with Japanese and Korean compa-
nies, which are international market leaders
(Cui, 2009, p.10). For strengthening domestic
TCM producers, research and development in-
centives such as the Regulations on Protection
of Traditional Chinese Medicines are appropri-
ate instruments.
Indian capacities for research and develop-
ment are considerably smaller than those of
the Chinese. For example, in 2009 the num-
57 Konstanzer Journal für Politik und Verwaltung
bers of patent applications and patents granted
in China were about sixty times higher than
those in India (WIPO, 2011). A strategy based
on patenting TK would rather benefit foreign
companies which make innovations based on
Indian TK quite frequently but outside India.
As India does not profit from those inventions,
it appears to be rational that the country tries
to prevent the transmission of TK and related
genetic resources to foreign countries. More-
over, benefit sharing mechanisms, established
by the Biological Diversity Act that are aided
by strict disclosure requirements for patents re-
lated to genetic resources, create economic ad-
vantages for India. Anyone who wants to profit
from TK related to Indian biodiversity by re-
ceiving a patent for an invention based on it
has to obtain permission from the NBA first.
The permission then establishes the terms and
conditions for the compensation of TK holders
(WTO, 2000). Thus, even if a foreign company
benefits from India’s TK heritage, this mech-
anism ensures the inflow of money into the
country.
Characteristics of traditional knowledge
itself
The characteristics of TK in each country also
certainly shape the margin of choice of decision
makers. For the case of China, the most im-
portant type of TK is TCM. TCM stems from
ancient traditions, but it has always been writ-
ten down in Chinese and is therefore accessible
for anyone able to read Chinese. Enforcing any
kind of benefit sharing mechanism would not
make sense for TCM, because it is part of the
common heritage of more than a billion peo-
ple. Thus, as Cui has pointed out, most leg-
islative proposals for TK protection in China
are lacking a convincing legal logic and, conse-
quently, appear to be more “like a kind of pro-
paganda” (2009, p.30). A second reason that
renders legal protection of TCM almost impos-
sible is its presence in other Asian countries,
such as Korea and Japan with both countries
sharing a long history of TMK utilization with
China. If TCM were to receive any kind of pro-
tection in China, it could still be freely used in
those countries, thus generating a strong com-
parative advantage for Korean and Japanese
companies (ibid., pp.34-35). Because TIK was
only of regional importance, it has not been
an issue on the public agenda for a long time.
However, industries for TMK products of eth-
nic minorities are rapidly growing (Zhang Li,
2007), which might explain the government’s
current interest in developing benefit sharing
laws.
In India, equally anciently codified TMK sys-
tems exist, which can be compared to the sta-
tus of TCM in China. However, this TK is
written down in a wide range of different lan-
guages. Only a few of these languages are still
spoken today. Unlike TCM, this knowledge
was therefore rather inaccessible in its entirety,
which made it vulnerable to misappropriation
by companies because patent examiners lacked
the possibility to screen it in their prior art
searches. Moreover, obtaining the revocation of
a once unjustly granted patent is difficult and
costly. The creation of the TKDL can be seen
as a direct reaction to these properties of tra-
ditional Indian knowledge (Oguamanam, 2008,
pp.498-499). India also has large amounts of lo-
cal and indigenous TK that is often of vital im-
portance to its holders (Sahai, 2003, p.166). This
might explain why India has been among the
first countries to amend its benefit sharing leg-
islation.
Ethnic composition of society
The role of ethnicity in each of the two coun-
tries is very closely related to the findings pro-
posed in the previous section. Usually, ethnic
boundaries also define holder groups of TK. In
India, there are 22 regional official languages
and many more tribes which also possess an
official status. Although some knowledge sys-
58 Christopher Schulz
tems have reached a predominant position (e.g.
the Ayurvedic medicinal knowledge), there are
many other TK systems which are of similar im-
portance, at least at a regional level (Sahai, 2003,
p.166). As the Indian state is built on the con-
cept of multi-ethnicity and respect for the rights
of indigenous communities, some recognition
is also given to the TK of ethnic groups; theoret-
ically, it is well protected under India’s Biologi-
cal Diversity Act. In sum, the ethnically diverse
Indian society has managed to create protection
mechanisms for all of its different kinds of TK,
i.e. for mainstream TK as well as local or in-
digenous TK.
By contrast, while China is also an ethnically di-
verse country, its society is dominated by one
single ethnic group, the Han Chinese. This
ethnic group makes up 92 percent of the total
population of the country. In addition, there
are 56 officially recognized ethnic groups in
China, but the majority Han generally hold
them in low esteem, characterizing them as
“backward”, “lacking culture” or “stuck at
earlier levels of social evolution” (Hathaway,
2010, p.307). The absence of a written ac-
count of their knowledge is considered to un-
derpin their derogative assumptions (ibid.). It
is plausible that China’s ethnic structure has
influenced the country’s strategy on TK. The
strategy addresses the needs of TCM indus-
try, but largely neglects TK of ethnic minori-
ties.
Public opinion and general awareness of
the issue
Because China is to a large extent dominated
by one ethnic group, one can assume that pub-
lic opinion on TK protection is mainly con-
cerned about their TK, i.e. TCM. This is fa-
cilitated by the ample infrastructure of TCM.
There have been several reports on cases of
misappropriation of TCM in the Chinese me-
dia. However, some of the most important al-
legations have proven to be baseless (Cui, 2009,
p.21). Most Han Chinese are probably not con-
cerned with TIK protection, which contributes
to its marginalization. Nevertheless, there are
some regional NGOs in the southeast of China,
where a large number of ethnic minorities live,
which try to conserve and protect TIK (Hath-
away, 2010, p.305).
In India, the situation is quite different. A
large number of very well-organized NGOs ex-
ist at the national and local level. This was
probably induced by several grave cases of bio-
piracy which India suffered. In any case, these
instances of misappropriation have decisively
shaped public opinion on this issue in India.
There was extensive international media cov-
erage on these cases supplementing the call
for TK protection by scholars, IGOs and NGOs
around the world. Being aware that local TK
is severely endangered, many regional NGOs
collect it and register its holders. This provides
a solid basis for future benefit sharing agree-
ments while cooperation between state author-
ities and these NGOs already exists (WTO,
2000).
Foreign policy interests
Finally, foreign policy interests of the two coun-
tries can be suspected of being driving forces
for the choice of national strategies on TK pro-
tection. India, jointly with Brazil and other
Latin American countries has taken a leader-
ship role in this arena by making proposals
in several IGOs to include obligatory benefit
sharing mechanisms and disclosure of source
and origin requirements into the TRIPS agree-
ment. Although China has sometimes joined
these groups, its political leaders have not ap-
peared to be very convinced of these propos-
als. They seem to prefer the status quo to
any “immature rule that would surprise inter-
ested industries” (Cui, 2009, p.2; p.30). By con-
trast, in a discussion on the protection of TK
in the WTO’s TRIPS Council, the representa-
tive of India made about 20 statements argu-
59 Konstanzer Journal für Politik und Verwaltung
ing in favour of including the above-mentioned
rules into TRIPS, his opponent being the rep-
resentative of the United States. China’s rep-
resentative only made one statement in which
he agreed with the United States, but also
with some of the developing countries’ cri-
tique (WTO, 2005). Furthermore, until 2005,
India had participated in the submission of
13 documents relating to TK protection within
the WTO, while China entered the debate
with only one submission (WTO, 2006, pp.20-
24).
Arguably, it can be assumed that economic in-
terests, as well as national differences such as
the characteristics of TK itself, the ethnic com-
position of society, and the public opinion and
general awareness of the issue add up to each
countries’ international position. Nevertheless,
their proceedings are coherent with superior
foreign policy interests. China is a hybrid of a
developing and a developed country as there
are enormous differences within the country
(CIPR, 2002, p.2). To define China’s position
in the field of TK protection, one can locate the
country in the middle of a continuum of no con-
cern or initiatives in the field to high concern and
many initiatives in the field. The first extreme ap-
plies to the United States, which is the only rel-
evant country not having signed the CBD. The
other pole applies to India, which was among
the first countries to sign CBD and to amend
national legislation to implement it. China is
situated in-between these two extremes, be-
cause it has intended to protect TK, but is cur-
rently only developing its own national legisla-
tion in this field. In this sense, it is safe to ar-
gue that India is several years ahead of China
with respect to TK protection. This strategy
ensures that China can keep its median posi-
tion between developed and developing coun-
tries while avoiding offending either group. On
the contrary, India has clearly positioned itself
as an advocate of interests of developing coun-
tries and has been active in exporting its TKDL
model to other developing countries (Ogua-
manam, 2008, p.504). One can suppose that In-
dia’s history of colonization has played a cru-
cial role within this development to a more
conflictive attitude towards the so-called first
world. Hence, bio-piracy by Western compa-
nies has many times been labelled as West-
ern colonization of our times by Indian activists
(Shiva, 1997, p.5).
Conclusions
“India scored a stunning victory over China
[. . . ] on a turf that is likely to become a ma-
jor battleground - bio-piracy or the theft of tra-
ditional flora, fauna and knowledge forms.”
(Chaulia, 2010) This recent quote of an In-
dian associate professor of world politics on
two Chinese patents on medicinal herbaceous
plants that were revoked by the European
Patent Office highlights the relevance of this ar-
ticle. Conflicts on the utilization of TK are still
to reach their peak and India and China are
central actors on this “battleground”. The use
of the above-mentioned plants have been de-
scribed in more than one thousand years old
Ayurveda texts, which were made accessible
to European patent examiners via the TKDL
(ibid.). On the one hand, this means that In-
dia has been successful in its anti-appropriation
strategy. On the other hand, the Chinese com-
pany which had filed for these patents has
proven to be at the same level of development
like its Western counterparts. This is the de-
clared aim of China’s political elite and this is
also reflected in China’s TK protection strat-
egy of promoting innovation and integration of
TCM into modern Western science. The aim of
this article has been to propose explanatory fac-
tors for the differences between the Indian and
Chinese strategies in the field of TK protection.
The analysis of the differences between these
two countries could not based on reliable sta-
60 Christopher Schulz
Table 1: Differences in national policy choices with respect to TK protection in India and
China and possible explanatory factors
Country Strategy Characteristics
Economic In-
terests
Characteristics
of TK itself
Ethnic com-
position of
society
Public opin-
ion and
general
awareness of
the issue
Foreign pol-
icy interests
India Defensive
protection
of TK, anti-
appropriation
strategy
Low inter-
national
competitive-
ness (with
respect to
research and
develop-
ment)
Diverse, in-
accessible
Diverse High aware-
ness and
understand-
ing of the
issue, high
number of
NGOs
Representing
developing
countries’
interests
China Positive
protection of
TK, strategy
of integrat-
ing TK into
Western
science
High in-
ternational
competitive-
ness (with
respect to
research and
develop-
ment)
Dominance
of TCM,
accessible
Dominance
of one group
Some aware-
ness, but less
understand-
ing of the
issue, few
NGOs, focus
on TCM
Representing
neither de-
veloping nor
developed
countries’
interests
tistical data, as the topic is far from being well-
explored and lacks literature with a clear polit-
ical science focus. This article should be con-
sidered as a first step on the way of analysing
interests and processes in the context of TK pro-
tection. Further research is therefore highly
desirable to verify the findings presented in
this article. Particularly field studies and data
collection on public opinion, the misappropri-
ation of TK, as well as on its economic and
social relevance seem to be a promising path
for future research. This would not only al-
low to explicitly taking up a political science
perspective on this topic, but also to answer
the question whether it is money or pride that
motivates governments and people to protect
TK.
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