Gomez and Krishnasamy 2019 A rapid assessment of the trade in Saiga Antelope horn in Peninsular Malaysia April 2019

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TRAFFIC Bulletin Vol. 31 No. 1 (2019) 35
S H O R T R E P O R T
Introduction
Saiga Antelopes Saiga tatarica are facing a
perilous future as their numbers in the wild
continue to decline. The taxonomy of the Saiga
Antelope has been subject to several changes
over the years and in the past populations
were split into two distinct species i.e. S. tatarica and
S. borealis. However, based on the current IUCN Red
List of Threatened Species, the Saiga Antelope treated
as a single species is now split into two sub-species:
fragmented populations of S.t. tatarica occurring in
Kalmykia in Russia and Kazakhstan, and S.t. mongolica
(equivalent to S. borealis) occuring in western Mongolia
(IUCN SSC Antelope Specialist Group, 2018). Their
original range has greatly reduced, with populations in
Ukraine and China now extinct; in Russia, they occur in
the steppes north-west of the Caspian Sea in Kalmykia
and in parts of the Astrakhan Region; in Kazakhstan, they
can be found in the Ural region, Betpak-dala and Ustyurt;
migrating populations are no longer seen in Turkmenistan
and those reaching Uzbekistan have declined; and in
Mongolia, populations are found only on the Shargiin
Gobi and Huisiin Gobi, the Mankhan area and Dorgon
steppe (IUCN SSC Antelope Specialist Group, 2018).
With herds historically numbering in the millions,
the global population of the Saiga Antelope is said to
have declined by over 95% since the early 1990s due
to hunting and exploitation for trade (Milner-Gulland et
al., 2001; Mallon, 2008; IUCN SSC Antelope Specialist
Group, 2018). Although the species could recover its
numbers rapidly, in more recent times, Saiga Antelope
populations, particularly in Kazakhstan and Mongolia,
also plummeted due to disease outbreaks (Frankfurt
Zoological Society et al., 2016; Saiga Conservation
Alliance, 2017). The dramatic decline in wild populations
resulted in the species being assessed as Critically
Endangered by the IUCN Red List of Threatened Species
in 2002 (Mallon, 2008). As of January 2018, the global
population of Saiga Antelopes was estimated at 164,600–
165,600 (IUCN SSC Antelope Specialist Group, 2018).
The Saiga Antelope is coveted for its horns which
are used in traditional Asian medicine and its meat is
consumed for food (Milner-Gulland et al., 2001; Lishu et
al., 2007; Mallon, 2008; Theng et al., 2017; Lam, 2018).
As the horns are an exclusive (and permanent) feature of
the male Saiga, selective hunting to supply this demand
has skewed the sex ratio among wild populations,
making breeding and ultimately species survival more
dicult. If unmanaged, the trade in Saiga Antelopes
could contribute to the extinction of an already imperilled
species. In South-east Asia, this trade is most prevalent
in Malaysia and Singapore, where Saiga Antelope horn
is promoted in medicine for its “cooling eect” despite
limited evidence of its ecacy (Chan, 1995; Theng and
Krishnasamy, 2017). During the 1990s in particular,
large quantities of Saiga horn were imported to Malaysia
and Singapore (S. Broad, pers. comm, April 2019).
During a survey on the availability of bear bile products
in traditional Chinese medicine (TCM) outlets across
Peninsular Malaysia in 2018, incidental observations of
Saiga Antelope horn products were noted. It appeared to
be one of the most common medicinal products derived
from wildlife to be observed in trade, alongside bear bile
pills and porcupine bezoar. This paper presents ndings
from the survey on Saiga Antelope horn availability in
Peninsular Malaysia and provides an insight into its
current open trade.
Background
International governance
In 1995, the Saiga Antelope was listed in Appendix II
of the Convention on International Trade in Endangered
Species of Wild Fauna and Flora (CITES) to ensure strict
regulation of the international trade in Saiga parts and
derivatives. Continued declines however led to a hunting
ban in all range States, implemented during dierent
periods between 1999 and 2014 (Theng and Krishnasamy,
2017). This eectively means that no legal horn export
has been permitted from range countries since then. Trade
however is permitted by some non-range States from
stocks acquired prior to these bans, with a valid permit.
In December 2018, Mongolia submitted a proposal for
consideration by CITES Parties at the 18th meeting of
the Conference of the Parties, to transfer Saiga tatarica
from CITES Appendix II to Appendix I to prohibit all
international commercial trade. The proponents of the
proposal explain that this is intended to help ensure that
international commercial trade will not contribute to
further declines, and to help range, transit and importing
CITES Parties to combat any illegal trade where newly
hunted Saiga Antelope products may be laundered
through stockpiles (CITES, 2019).
The Saiga Antelope is also listed in Appendix II of the
Convention on the Conservation of Migratory Species of
Wild Animals (CMS, or the Bonn Convention). A CMS
Appendix I- and II-listing obligates Parties to, inter
alia, prohibit the taking of Appendix I species (unless in
exceptional cases) and conclude international agreements
which would benet Appendix II species. To this end,
a Memorandum of Understanding (MoU) concerning
the conservation, restoration, sustainable use of Saiga
N. SINGH / CC /LICENSES/BY-NC-SA/2.0/
A rapid assessment of the trade in
Saiga Antelope horn in Peninsular Malaysia
Report by Lalita Gomez and Kanitha Krishnasamy
Saiga Antelopes Saiga tatarica.

S H O R T R E P O R T
36 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
Antelope Saiga spp. was adopted in September 2010
(CMS, 2010). Although not a Party to CMS, Malaysia
periodically provides reports to the Convention, which
contributes to the Medium-Term International Work
Programme (MTIWP) for the Saiga Antelope.
Legislation and regulation in
Peninsular Malaysia
In Peninsular Malaysia, trade in Saiga Antelope is
regulated under the Wildlife Conservation Act 2010
(WCA), which permits trade through a licensing system,
regulated by the Department of Wildlife and National
Parks Peninsular Malaysia (DWNP). The DWNP also
controls the management and distribution of stocks
that are permitted for trade. Any violations can incur a
minimum ne of MYR20,000 (USD5,000) or a maximum
ne of MYR50,000 (USD12,500), or imprisonment of
not more than one year, or both. Any import and export
violations are also covered under the country’s CITES
implementing legislation, the International Trade in
Endangered Species Act 2008 (INTESA). Anyone found
guilty of importing or exporting Saiga Antelope parts or
products without a valid licence is liable to a maximum
ne of MYR1million (USD250,000), or imprisonment to
a term not more than seven years, or both. If the violation
involves a corporate body, nes can reach MYR2million
(USD500,000).
The trade in traditional medicine (TM) is further
governed in Malaysia by at least three other laws.
The Traditional and Complementary Medicine Act
2016 regulates all traditional and complementary
medicine practitioners and services. The Traditional
and Complementary Medicine Council is the leading
body governing the implementation, regulation and
enforcement of the Act. Anyone found guilty of violating
the Act can be liable to a ne of MYR30,000 (USD7,500)
or two years’ imprisonment for the rst oence. Those
found not legally registered as a practitioner can also be
ned MYR50,000 (USD12,500), or imprisoned for up
to three years, or both, and may also be prohibited from
registering as a practitioner for a period of two years upon
conviction. The Sale of Drugs Act 1952 (Control of Drugs
and Cosmetics Regulation 1984), requires compulsory
registration of all pharmaceutical products, including
TM products containing wildlife derivatives. Products
must have adequate records and labels; applicants must
trace all steps of production and distribution and keep
these records for one year beyond the expiry date. The
general penalty for oending individuals is a maximum
ne of MYR25,000 (USD6,250) and/or imprisonment
for up to three years for the rst oence, and a maximum
ne of MYR50,000 (USD12,500) and/or ve years’
imprisonment for subsequent oences. Oending
companies are liable to a ne of up to MYR50,000
(USD12,500) for the rst oence, and MYR100,000
(USD25,000) for subsequent oences.
Methods
Incidental observations of Saiga horn products were noted
during a bear bile survey across outlets in Peninsular
Malaysia between April and May 2018. Open availability
was recorded and information such as prices and stock
were gathered opportunistically through conversations
with traders, though the actual volumes in trade were
dicult to record. All observations of trade claimed to
be of, or to contain Saiga horn derivatives, were assumed
to be genuine. This is in accordance with the WCA,
which states in Section 3: “part or derivative means any
States No. of Shops Types of Products Price (whole horn)
MYR USD
Johor 30 horns (whole), shavings, powders 2.67–12.00/g 0.65–2.93/g
bottled Saiga water, bottled Saiga tea - -
Kedah 11 horns (whole), shavings, powder (capsule) 8.00–18.67/g 1.95–4.55/g
Kelantan 11 shavings, powder - -
Melaka 28 horns (whole), shavings, powder 85.33/g 20.81/g
20.00–40.00/g 4.88–9.76/g
Negeri Sembilan 9 horns (whole), shavings, powder 0.56/g 0.14 g
120.00/g 29.27/g
Pahang 13 shavings, powder - -
Penang 12 horns (whole), shavings 6.67-8.00/g 1.63-1.95/g
208.00-224.00/g 50.73-54.63
Perak 33 horns (whole), shavings, powder, powder
mixed with pearl powder (capsule), concoction 4.00–9.00/g 0.98-2.20/g
Perlis 3 shavings, concoction - -
Terengganu 4 shavings, powder - -
Table 1. TCM outlets with Saiga Antelope horn products for sale by State in Peninsular Malaysia,
April–May 2018. - = prices not recorded; Note: observations from the State of Selangor and Federal Territory of Kuala Lumpur are not
included here as trade information was not recorded in a consistent or standardised manner, and therefore not included for analysis. Saiga
horns have however been recorded in trade in these two location in previous surveys of TCM outlets in 2006, and rapid checks on selected
shops in 2018 conrms this. Some outlets may have more than one form of Saiga horn product available. Price information is denoted based
on oers by traditional medicine stores.

TRAFFIC Bulletin Vol. 31 No. 1 (2019) 37
S H O R T R E P O R T
value quoted at ~MYR224/g (USD55/g), followed by
Negeri Sembilan with ~MYR120/g (USD30/g). Negeri
Sembilan also had the lowest price recorded with
MYR280/500 g (~MYR0.56/g), followed by Johor with
~MYR2.7/g. The large dierences in price could be an
indication of the authenticity of the product (with lower
prices indicating the substitution of other animal horns).
In comparison, prices recorded in 2006 ranged from a
minimum of MYR1.6–8/g (USD0.40–2/g), indicating a
signicant increase over the 12-year period.
CITES trade data analysis
According to the CITES Trade Database, between 1995
and 2017 Malaysia imported an average of 2,631 kg of
Saiga horn and exported 2,382 kg (Table 2). Countries
and territories that reported importing Saiga horns from
Malaysia were China, Hong Kong Special Administrative
Region (SAR), New Zealand, Singapore and the USA,
while countries and territories that reported exporting
Saiga horns to Malaysia were China, Hong Kong SAR
and Singapore.
No trade records were reported after 2015, and in
the last decade since 2005, Malaysia’s imports were
generally low, accounting for about 16% of its total
imports. Imports were mainly of horns from Singapore
and Hong Kong SAR, which were reported as pre-
Convention specimens. During this time, Malaysia also
(re)exported horns to Hong Kong SAR and Singapore
and derivatives to New Zealand and the USA.
Information from the CITES Trade Database also
suggests that at least 10 shipments of Saiga Antelope
horns and derivatives between 1998 and 2010 could
have been seized in the USA and New Zealand, reported
to have been exported from Malaysia. In two of these
records at least, the origin of the item was reported to
be China. These transactions are assumed to be seizures
upon import, as the source of the trade is indicated by the
Source Code “I”, i.e “conscated or seized specimens”.
Discussion and Conclusions
Although Malaysia is not party to CMS, which monitors
conservation (including trade) in migratory species such
as the Saiga Antelope, in its report to the Convention in
2015, the DWNP reported that 119.45 kg of horns were
imported from Kazakhstan, Singapore and Hong Kong
SAR that were declared as pre-Convention stocks (CMS,
2015). A further 10.8 kg of shavings and 365.5 kg in the
form of powder/slices was also reportedly imported. The
period of this import was unreported.
The DWNP maintains a database of registered dealers
through its licensing system. However, the number
of dealers permitted to trade in Saiga and the volume/
stockpile of Saiga horns and derivatives is unknown.
Permitted trade volumes are based on a trader’s
application for a dealer’s licence, and all sales must be
recorded in the dealer’s stock book (DWNP pers. comm.
to K. Krishnasamy, October 2018). It is not clear how
stocks are regulated or if stocks may have originated
from illegal imports. At the 66th meeting of the CITES
Standing Committee (SC66 Doc. 52) (CITES, 2016), it
was reported that one seizure of unknown origin took
place in Malaysia in 2012 consisting of horn cuttings
substantially complete or part or derivative of wildlife, in
natural form, stued, chilled, preserved, dried, processed
or otherwise treated or prepared, which may or may
not be contained in preparations, and includes anything
which is claimed by any person, or which appears from an
accompanying document, the packaging, a label or mark
or from any other circumstances, to contain any part or
derivative of wildlife”. Records of trade data extracted
from the CITES Trade Database are also included here to
provide records of international trade of Saiga Antelope
horns involving Malaysia. Results presented also
include comparison with information gathered during a
TRAFFIC survey of TCM outlets in Malaysia in 2006
(von Meibom et al., 2010).
Results
Market survey
Of 228 TCM outlets surveyed in 10 States across
Peninsular Malaysia, 154 (67.5%) were found to be
openly selling Saiga Antelope horn products (Table 1).
Horn shavings were the most common Saiga Antelope
product observed in trade, sometimes packaged with
herbs. Whole horns were available in some States,
although a couple of traders reported that genuine
Saiga Antelope horn is hard to come by and that some
TCM traders use the horns of goat, cow or bualo as
substitutes. Bottled water, a “tea” reported to contain
Saiga Antelope horn, and a bottled concoction reported
to consist of Saiga Antelope horn and pearl liquid were
also oered for sale.
TRAFFIC’s survey of 111 TCM outlets in ve
locations across Peninsular Malaysia in 2006 found
109 outlets (98%) with Saiga Antelope horn products or
derivatives for sale (von Meibom et al., 2010). Shavings
were the most common product available then (recorded
in all 109 TCM outlets) followed by horns (whole)—
over 800 horns were recorded in 68 outlets.
The price for Saiga Antelope horn during the present
survey varied quite considerably in each State. The
highest price was recorded in Penang with the maximum
INTERNATIONAL INTERNATIONAL
TRADE TO MALAYSIA TRADE FROM MALAYSIA
Source Importer Exporter Exporter Importer
MY (kg) (kg) (MY) (kg) (kg)
Pre-Convention
horns 1,582.09 2,904.24 608.12 717.12
Pre-Convention, wild
horns 112.60 140.85 338.60 1284.30
Wild
horns 80.10 374.34 374.34
derivatives 0.90
Wild/Pre-Convention
horns 50.00 59.00
Seized
derivatives 120.05
horns 0.02
Unknown
horns 302.60 30.00 948.40
Total 2,047.29 3,215.09 2,269.46 2,495.83
Table 2. Summary of import/exports of Saiga Antelope horns traded
with Malaysia (MY), 1995–2017. Source: CITES Trade Database.

S H O R T R E P O R T
38 TRAFFIC Bulletin Vol. 31 No. 1 (2019)
and medicinal products, and resulted in the prosecution
of three individuals. CITES trade data reveal a further
10 records that might be seizures implicating Malaysia
as a transit country in the international tracking of
Saiga-related products, with the majority of those
occurring from 2006–2010. A 2016 study of Singapore’s
international trade in Saiga revealed that the legal import
of horns had declined by 99% over the previous decade,
yet vast quantities of horns, reportedly from stockpiles,
were still being exported to Hong Kong SAR, China and
Malaysia (Theng et al., 2017). CITES trade data from
1995–2015 revealed that Singapore was the world’s
largest (re)exporter of Saiga horns, surpassing those
from Saiga range countries from where horns were also
imported by Malaysia (Theng and Krishnasamy, 2017).
Von Meibom et al. (2010) further concluded that Saiga
horns were illegally being exported from Malaysia
although the volume and signicance of this trade was
unknown.
This study conrms an active trade in Saiga Antelope
horns and derivatives in Peninsular Malaysia. While
trade is permitted, it is unclear what proportion of this
trade is occurring in accordance with regulations, or
otherwise, or indeed whether the products are always
genuine. The discrepancies in trade data and the lack of
information on stocks in the country—either quantities
held by traders, those maintained in government custody
and those privately-held, if any—make it impossible
to ascertain current legal stocks permitted for trade.
More comprehensive reporting to CITES and CMS
would facilitate this. A detailed study on the stocks
and consumption of Saiga Antelope horns in Malaysia
would also provide better and more accurate insights
into current consumption and demand patterns, to
guide awareness raising and demand reduction-related
activities, as appropriate. These eorts should be
undertaken collaboratively between governments, NGOs
and, importantly, with the traditional Chinese medicine
dealers and practitioners in the country.
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Acknowledgements
The authors thank Chris R. Shepherd and Stephanie von
Meibom for their comments on an earlier draft and Hauser
Bears for generously funding and supporting TRAFFIC’s work
on wildlife trade in Malaysia.
Lalita Gomez, Programme Ocer, Monitor Conservation
Research Society. E-mail: lalita.gomez@mcrsociety.org;
Kanitha Krishnasamy, Director, Southeast Asia Oce,
TRAFFIC; E-mail: kanitha.krishnasamy@trac.org
Shavings purported to be from Saiga Antelope
horn, on sale in a traditional medicine outlet in
Peninsular Malaysia in 2018.
© TRAFFIC