An update on the bear bile trade in Peninsular Malaysia

Abstract

One of the key threats to Sun Bears in Malaysia is the illegal wildlife trade. Malaysia is a key source and consumer of bear bile products in Asia and its wild bear populations continue to be poached to meet the demand for traditional Chinese medicine (TCM). Surveys were conducted in 2017 and 2018 of TCM outlets in Peninsular Malaysia to monitor and assess the open availability of bear bile products in the market which is compared with similar surveys undertaken in 2012. This study revealed that the illegal trade in bears persist in violation of national laws and international regulations despite numerous initiatives taken to disrupt it. There was little change in relation to the availability or types of products available in the market when compared to previous surveys undertaken in 2012 with the exception of the decrease in the number of TCM retailers selling bear gall bladders. However, it was also clear that most retailers surveyed were aware that the trade in bears was strictly prohibited in Malaysia in comparison to previous years. This is a concern as it is increasing less clear whether the illegal trade in bears and their parts has decreased or whether retailers have become more adept at circumventing the law. As such it is recommended more resources need to be centred on enforcement efforts encompassing in depth monitoring and pro-active investigation into the illegal trade of bears for traditional medicine. Furthermore, consumers, knowingly or unwittingly, contributing to this demand are an aspect that has yet to be addressed in Malaysia. Efforts to better understand consumer behaviour is therefore critical in determining the next steps that can lead to reducing demand for bear bile products and more legal and responsible purchasing of TCM products that contain wildlife.

Full text

AN UPDATE ON THE
PENINSULAR
MALAYSIA
TRADE IN
BEAR BILE
Lalita Gomez
OCTOBER 2019

TRAFFIC is a leading non-governmental organisation
working globally on trade in wild animals and plants
in the context of both biodiversity conservation and
sustainable development.
Reprod uction of material appearing in this report
requires written permission from the publisher.
The designations of geographical entities in this
publication, and the presentation of the material, do not
imply the expression of any opinion whatsoever on the
part of the authors or their supporting organisations
concerning the legal status of any country, territory, or
area, or of its authorities, or concerning the delimitation
of its frontiers or boundaries.
Published by:
7SYXLIEWX%WME6IKMSREP3ƾGI4IXEPMRK.E]E1EPE]WME
ISBN:
Suggested citation: Gomez. L (2019). An update on the
bear bile trade in Peninsular Malaysia, Southeast Asia
6IKMSREP3ƾGI4IXEPMRK.E]E4IRMRWYPEV1EPE]WME
© TRAFFIC 2019. Copyright of material published in
this report is vested in TRAFFIC.
UK Registered Charity No. 1076722
Design by Marcus Cornthwaite
TRAFFIC REPORT
An update on the bear bile trade
in Peninsular Malaysia

CONTENTS
/I]ƼRHMRKW
1
Results
Introduction
Discussion and conclusions
Survey results
Commodity types
References
Image credits
2
2
3
4
7
2
14
8
9
17
18
ACKNOWLEDGEMENTS
1ER]XLEROWXS'LVMW67LITLIVH/ERMXLE/VMWLREWEQ])PM^EFIXL.SLR7XIZI&VSEHERH.EQIW
Compton for their feedback on an earlier draft, to Richard Thomas for his review of the report,
1EVGYW'SVRXL[EMXI JSV HIWMKRERH PE]SYXERHXS XLI ƼIPHVIWIEVGLIW JSV XLIMVMRZEPYEFPI XMQI
and effort in undertaking the surveys. Much appreciation is also owed to Hauser Bears for their
generous funds to TRAFFIC that made this project possible.
Protection status
Methodology
1
5
6

1An update on the bear bile trade in Peninsular Malaysia
One of the key threats to Sun Bears Helarctos
malayanus in Malaysia is illegal wildlife trade.
Malaysia is a key source and consumer of
bear bile products in Asia and its wild bear
populations continue to be poached to meet
the demand for traditional Chinese medicine
(TCM). Surveys were conducted in 2017 and
2018 of TCM outlets in Peninsular Malaysia to
monitor and assess the open availability of bear
bile products in the market compared to similar
surveys undertaken in 2012. This revealed that
the illegal trade in bears persists in violation
of national laws and international regulations
despite numerous initiatives taken to disrupt it.
There was little change in relation to the
availability or types of products in markets
compared to previous surveys undertaken
in 2012 with the exception of the decrease in
the number of TCM retailers selling bear gall
bladders. However, it was also clear that most
retailers surveyed were aware that the trade
in bears was strictly prohibited in Malaysia in
comparison to previous years. However, it is
unclear whether the illegal trade in bears and
their parts has decreased or whether retailers
have become more adept at circumventing
the law. As such it is recommended that more
resources are committed to enforcement
efforts encompassing in depth monitoring and
proactive investigation into the illegal trade of
bears for traditional medicine. Furthermore,
the degree to which consumers knowingly
or unwittingly contribute to this demand has
yet to be addressed in Malaysia. Efforts to
understand consumer behaviour better are
therefore critical in determining the next steps
that can lead to reducing demand for bear bile
products and legal and responsible purchasing
of TCM products that contain wildlife.
between 2000–2018
62 bear-related seizures
took place in Malaysia
MRZSPZMRK
100 animals
of surveyed shops
69.5%
were found to be selling, or
potentially selling, bear products
KEY FINDINGS

2
An update on the bear bile trade in Peninsular Malaysia
INTRODUCTION
Sun Bears Helarctos malayanus are Malaysia’s only native bear species and are threatened
by poaching and trade to meet demand for traditional medicine, food and pets. A total of 62
bear-related seizures took place in Malaysia from 2000–2018, involving over 100 animals.
Seizures involved live bears and parts (gall bladders, paws and canines). Aside from
seizures, in more recent times, bears have increasingly been found butchered with their
paws and gall bladders removed, trapped in snares (Or et al., 2017), and advertised on social
media websites, with posts of live cubs openly for sale (Kanyakumari 2015, Krishnasamy
and Stoner 2016, TRAFFIC 2016).

3An update on the bear bile trade in Peninsular Malaysia
Assessments of the trade in bear parts and derivatives in Malaysia
over the past 20 years have revealed the country as a key source
and consumer of illegally obtained bear parts and products, which
are derived from the Sun Bear as well as the Asiatic Black Bear
Ursus thibetanus (Mills and Servheen 1994, Pereira et al., 2002,
Shepherd and Shepherd 2010, Foley et al., 2011, Burgess et al.,
2014, Krishnasamy and Shepherd 2014, Lee et al., 2015, Or et al.,
2017). These studies were undertaken to draw attention to the
scale of the illegal trade and provide mitigating actions to reduce
the detrimental impacts on wild bear populations in the country,
and also to provide evidence for law enforcement action.
86%**-'ƼVWXWLIHPMKLXSRXLIMWWYIMR[MXLE TVIGYVWSV]
look at bear products available in 13 traditional Chinese medicine
(TCM) shops in the country (Mills and Servheen 1994). Nine of
these shops offered whole gall bladders said to be from Borneo,
China, Nepal, and Thailand, while the remaining four shops
offered bear bile in the form of capsules. There was evidence of
MPPIKEP MRXIVREXMSREP XVEHI [MXL PSGEPW XVEƾGOMRK 7YR &IEV TEVXW
to destinations including Hong Kong, Singapore, Taiwan, and
Thailand.
In 1997, Meijard (1999) reported that nearly every TCM shop in the
State of Sarawak had gall bladders in stock, whereas in Sabah it
was more discreet with traders reporting they were prohibited in
selling protected species.
In 2001, TCM shops were surveyed by the World Society for
the Protection of Animals (WSPA), across several States in the
country for trade in bears and their parts (Pereira et al., 2002).
They found 57 out of 73 shops (78%) visited had gall bladders,
bear bile powders and other medicines manufactured from bear
bile. Over 90 gall bladders were observed for sale derived from
wild bears in Malaysia and to a lesser extent Indonesia, whereas
the manufactured bear bile medicine was reported to be from
bear farms in China. The States of Sabah and Sarawak had a
higher prevalence of whole gall bladders whereas manufactured
bear bile medicine was more common in Peninsular Malaysia as it
was reportedly easier to get past authorities (Pereira et al., 2002).
At that time, the wildlife legislation of Peninsular Malaysia had no
prohibition on selling “derivatives” of protected species (Shepherd
2006). This loophole was amended in 2010, after which it also
became an offence to sell any product claimed to contain any part
of a protected species or its derivatives.
a timeline
OF TRAFFIC AND OTHER SURVEYS
1991
TRAFFIC survey of 13
TCM shops in Malaysia
shops offered
whole gall bladders
shops offered bear
bile capsules
9
4
1997
a Meijard report on
TCM shops
SARAWAK: almost every TCM
shop stocked gall bladders
SABAH: sale was more discreet,
traders report prohibition
2001
WSPA survey of 73 shops
across several States
shops sold gall bladders,
bile, and other medicines
78%
TRAFFIC survey of 292 TCM shops in
Peninsular Malaysia, Sabah, Sarawak
2010
shops sold gall bladders,
bile, and other medicines
77%
including 160+ whole gall bladders,
ERHFMPITMPPWƽEOIWERHQIHMGMRIW
TRAFFIC survey of 365 TCM
shops in all States of Malaysia
2012
openly sold bear bile
products
48%
~65%: products on sale were
bear bile pills
~48%: products on sale were
gall bladders
of products were said to
be locally sourced
60%

4
An update on the bear bile trade in Peninsular Malaysia
Subsequently, in 2010, TRAFFIC surveyed 292
TCM shops in selected parts of the country
(covering Peninsular Malaysia, Sabah and
Sarawak) and found 77% of shops still sold bear
bile products (Foley et al., 2011). This included
gall bladders (over 160 recorded) and medicine
MI TMPPW ƽEOIW SMRXQIRX QERYJEGXYVIH JVSQ
bear bile. Further, it was reported that many
of the traders were aware that selling bear bile
products was illegal, revealing little fear of law
enforcement (Foley et al., 2011). They also
found that while much of manufactured bear
bile medicine was still being imported from
China, there was a larger percentage of products
reportedly of Malaysian origin available in
comparison with previous years.
TRAFFIC undertook a follow-up survey in 2012,
visiting 365 TCM shops covering all States and
territories across Malaysia (Lee et al., 2015).
Findings revealed close to half (i.e. 48%) of the
TCM retailers surveyed still openly claimed to
be selling authentic bear products. Much of this
was in the form of bile pills (~ 65%) and whole
gall bladders (~ 43%) and to a lesser extent,
TYVIFMPII\XVEGXƽEOIWHVMIHKEPPFPEHHIVWOMR
and other manufactured products. As with
previous studies, gall bladders observed for
sale were apparently mostly locally sourced
(60%) and were provided to the TCM retailers
through opportunistic or deliberate poaching by
indigenous people or illegal imports from China.
The sale of bear gall bladders observed in 2012
was more discreet than in previous surveys (i.e.
not on open display, hidden in different rooms,
or stored in a different location altogether).
Notably, there were retailers who reported a
dramatic decline in demand for bear products
attributed to consumers preferring cheaper
alternatives and to a younger generation that
favoured conventional/western medicines.
There were also retailers who continued to
stock gall bladders to supply regular customers.
Exposure of the TCM industry in Malaysia in
such a negative light spurred the Federation
of Chinese Physicians and Medicine Dealers
Association of Malaysia (FCPMDAM) to
begin a dialogue with TRAFFIC, and this was
considered a major step in the right direction
towards conservation of bears in the country. In
2015, TRAFFIC began working with FCPMDAM
to raise awareness among TCM practitioners
of the illegality of prescribing medicine that
contained protected species, encouraging
them to protect their reputation by practicing
[MXLMRXLIGSRƼRIWSJXLIPE[-R86%**-'
organised a conference for TCM practitioners
in Malaysia, with the purpose of introducing
herbal alternatives that are just as effective,
if not more so, than bear bile (Gomez 2017).
TRAFFIC also initiated a dialogue with the
National Pharmaceutical Control Bureau of the
Ministry of Health in Malaysia, highlighting the
crucial role that it plays in screening traditional
medicinal products entering the market, and
with local enforcement authorities to support
their efforts to disrupt the illegal bear trade.
Research for this report was undertaken as
part of TRAFFIC’s continuing efforts to support
action to end the illegal trade in bears and
ensure Malaysia remains a stronghold for wild
Sun Bear populations.

5An update on the bear bile trade in Peninsular Malaysia
Sun Bears are categorised as a “Totally
Protected” species in Peninsular Malaysia and
Sabah, while in Sarawak they are only listed as
“Protected” and can be hunted with a special
licence (Krishnasamy and Shepherd 2014).
Sabah amended its law in 2016, the Wildlife
Conservation Enactment (Amendment) 1997,
allowing for higher penalties for offences
involving Totally Protected species, such as
XLI 7YR &IEV [MXL ƼRIW RS[ MR XLI VERKI SJ
MYR50,000–250,000 (USD11,700–58,400),
plus imprisonment of 1–5 years. In Peninsular
Malaysia, the Wildlife Conservation Act 2010
EPVIEH]MQTSWIWELMKLƼRIJSVSJJIRGIWMRZSPZMRK
the Sun Bear—up to MYR300,000 (USD70,000)
along with a jail term of not more than 10
years—however the rate of arrest and conviction
could be improved. In contrast, Sarawak has
done little, with its Wild Life Protection Ordinance
1998 remaining the weakest in the country for
XLI TVSXIGXMSR SJ 7YR &IEVW [LIVI ƼRIW JSV
violations only reach MYR10,000 (USD2,500) and
a one year jail term. The Sun Bear is also listed
in Appendix I of the Convention on International
Trade in Endangered Species of Wild Fauna
and Flora (CITES), prohibiting any international
commercial trade in the animals, including Sun
Bear parts or products. According to Malaysia’s
CITES implementing legislation, the International
Trade in Endangered Species Act 2008 (INTESA),
the penalty for illegally importing or exporting
'-8)7PMWXIH WTIGMIW GEVVMIW E ƼRI SJ YT XS
MYR1 million (USD250,000) for an individual or
MYR2 million (USD500,000) for businesses, and
a maximum imprisonment of up to seven years.
PROTECTION STATUS
“TOTALLY PROTECTED”
IN SABAH
“PROTECTED”
IN SARAWAK
USD11,700–58,400
ƼRIJSVSJJIRGIW
involving Sun Bears, plus
imprsonment of between
1–5 years
USD2,500
ƼRIJSVSJJIRGIW
involving Sun Bears,
plus imprsonment of 1
year
“TOTALLY PROTECTED”
IN PENINSULAR MALAYSIA
UP TO USD70,000
ƼRIJSVSJJIRGIW
involving Sun Bears, plus
imprsonment of up to 10
years

6
An overview of major global shark traders, catchers and species
&IX[IIR.YRIERH1E]8'1SYXPIXW
in all 11 States within Peninsular Malaysia
and the federal territory of Kuala Lumpur were
surveyed. The survey was limited to Peninsular
Malaysia, unlike the 2012 survey which included
Sabah and Sarawak in Malaysian Borneo. The
survey encompassed all TCM outlets previously
surveyed in 2012 with the exceptions of
those which have since closed down or could
not be located, and new additional outlets
not previously discovered. This survey was
undertaken as a follow-up to the 2012 survey on
availability of bear parts and products in TCM
outlets, recording presence/absence of bear
products only (and does not include quantities,
turnover rates or efforts to verify authenticity of
products claiming to contain bear).
In keeping with previous methodology, the
survey was conducted by researchers posing
as a potential customer enquiring about bear
gall bladder or bear bile products available for
sale. While authenticity of a product could not
FI ZIVMƼIH F] WYVZI] EPSRI XLI EZEMPEFMPMX] SJ
products on sale (absence/presence) is based
on retailers’ responses to the researchers: if a
retailer did not explicitly say they did not sell
bear bile products, it was assumed that there
was a possibility the product on display or
presented to the researchers contained bear
bile. Photographs of products were taken where
possible. TCM outlets found selling or that
claimed to be selling bear gall bladders and
derivatives were reported to the relevant law
enforcement agency (i.e. Department of Wildlife
and National Parks for each State/territory) for
their further action, and to the FCPMDAM that
they might check their members’ commitment
XSTVEGXMGMRK[MXLMRXLIGSRƼRIWSJXLIPE[
METHODOLOGY

7An update on the bear bile trade in Peninsular Malaysia
RESULTS

8
An update on the bear bile trade in Peninsular Malaysia
A total of 318 TCM outlets were surveyed of
which 221 (69.5%) were found to be possibly
selling bear parts and derivatives. Pills (88%)
were the most common product found on
sale followed by gall bladders (7%) and to a
much lesser extent, powder, vials and ointment
(above). However, it is unclear whether these
pills do in fact contain bear bile due to varied/
inconsistent claims by retailers and labelling,
or a lack thereof, on some products. In 2012,
pills (65%) were also the most common and
abundant product recorded and similar types
of pill products were observed for sale during
this current survey (refer to Lee et al., 2015).
According to retailers, the pills were mostly
imported from China (n=169 retailers), although
40 TCM retailers claimed to have a local supplier.
In most cases, details on local suppliers were
not provided to TRAFFIC researchers. That
said, at least two retailers in Penang claimed
to be suppliers of bear bile products to TCM
outlets across Peninsular Malaysia. This was
ZIVMƼIHF] EXPIEWXXLVIIVIXEMPIVW[LMPI SXLIVW
GPEMQIH XLIMV WYTTP] GEQI JVSQ .SLSV R!
retailers) or Kuala Lumpur (n=2).
SURVEY RESULTS
TCM shops
318
were surveyed between
June 2017 and May 2018
69.5%
were found to be possibly
selling bear parts and derivatives
(221)
BEAR BILE PRODUCT
BREAKDOWN
PILLS
GALL BLADDER
88%
7%
3%
VIALS
0.5%
OINTMENTS
POWDER
1%
GALL BLADDER
(CAPSULE)
0.5%
Different types of bear bile products found in TCM outlets (n=221) in Peninsular Malaysia,
between June 2017 and May 2018: While the majority of bear bile products for sale were in the form
of pills, researchers were uncertain as to their authenticity. This was mainly due to the fact that while
some pills were labelled as bear bile, many retailers claimed the ingredients consisted also of herbs
and other animal bile; others reported that they contained a small percentage of bear bile mixed with
other animal bile and herbs; and in some cases, the same product was claimed by retailers as both
containing and not containing bear bile.

9An update on the bear bile trade in Peninsular Malaysia
There were very few retailers who claimed to
have pure bear bile pills (n=22 retailers). Rather,
most retailers selling bear bile pills made it
known to the researchers that the government
prohibits the sale of products containing bear
bile and that the killing of bears is not allowed.
In comparison, in 2012, nearly half of all retailers
surveyed claimed to be selling authentic bear
bile products (n=175 retailers). In this study,
there were at least two retailers in Penang
who reported that any purchases of bear bile
TVSHYGXW [SYPH RSX FI VIƽIGXIH MR VIGIMTXW
They also noted that while some products are
still labelled with the Chinese words - 熊胆药丸
or 金丝熊胆丸 (bear bile pill or golden silk bear
bile pill), the pills themselves only contained a
mixture of herbs and/or other animal bile (e.g.
chicken, pig, snake, cow) and/or pearl powder
and claimed to have the same effect as actual
bear bile (Figs. 1–5). Other retailers claimed
the product was pure bear bile while some said
there was no bear bile in the product at all. It
should be noted that not all pills were packaged
with labels and on some that did have labels the
term bear bile was not used and neither was
it listed as an ingredient. Whether these pills
actually contain bear bile or not has yet to be
GSRƼVQIHEWXLMWGERSRP]FIZIVMƼIHXLVSYKL
forensic DNA testing.
Of those that were not selling bear bile (n=97),
at least two traders claimed to be out of stock
at the time of the survey.
FIGURE 1
The commonest type of “bear bile pills” found in markets were described as being mixed herbs, bile
from other animals, or pearl powder. No photos or labels on the packaging related to bear bile or
gall bladder products.
9An update on the bear bile trade in Peninsular Malaysia

10
An update on the bear bile trade in Peninsular Malaysia
FIGURE 2
For some products only the Chinese characters 熊胆 (which translates as “bear bile”) are used.
Some retailers said this was bear bile mixed with herbs while others claimed there was no bear bile
in the product at all.
FIGURE 3
Pure bear bile reportedly imported from (i) China and (ii) Korea.
10
An update on the bear bile trade in Peninsular Malaysia

11 An update on the bear bile trade in Peninsular Malaysia
One of the few products reported by traders to be pure bear bile.
FIGURE 4
Whole gall bladders for sale in TCM outlets —the one on the right is supposedly 10 years old and the
retailer’s last stock of bear gall bladder.
FIGURE 5
11 An update on the bear bile trade in Peninsular Malaysia

12
An update on the bear bile trade in Peninsular Malaysia
Gall bladders claimed to be from bears were found for sale in 16 of the TCM outlets surveyed (Fig.
5), although quantities were not determined. There were a further two retailers willing to source for
gall bladders on request. At least seven retailers claimed the gall bladders were locally sourced,
while two reported Indonesia as the origin. In 2012, at least 57 TCM outlets surveyed in Peninsular
Malaysia had gall bladders for sale estimated at 155 gall bladders (averaging 2-3 gall bladder per
TCM shop). In general, an increase in TCM shops selling bear bile products (genuine or otherwise)
were recorded during 2017–2018 compared to surveys in 2012, but fewer shops with actual bear
gall bladders (Fig.6).
0
10
20
30
40
50
60
70
80
90
100
0
50
100
150
200
250
1991 2001 2010 2012 2017/2018
Percentage
NumberSJSYXPIXW

TCM outlets selling bear productsTCM outlets RSXselling bear products% shops selling
Comparison of results between surveys conducted with varying effort in Peninsular Malaysia. It
should be noted that the majority of products recorded for sale have consistently been pills in which
EYXLIRXMGMX]LEWRSXFIIRZIVMƼIH,S[IZIVJEVJI[IVWLSTW [IVI JSYRH WIPPMRKFIEVKEPPFPEHHIVW
during the present survey in comparison to previous years.
FIGURE 6
The percentage of shops found with some form of bear bile product during this survey was almost
70% in comparison to 2012 when it was 48%. Again, it should be noted that most retailers claimed
that the bear bile pills for sale were mostly herbal in nature or a mixture with other animal bile. The
Federal Territory of Kuala Lumpur and Selangor had the highest proportion of shops found with
FIEVFMPITVSHYGXWJSPPS[IH F].SLSVERH4IVEO*MK7MQMPEV ƼRHMRKW [IVIVIGSVHIHMR
with Perak having the highest number of shops selling bear bile products (n=27 shops), followed by
.SLSVR!WLSTWERH/YEPE0YQTYVR!WLSTW

13 An update on the bear bile trade in Peninsular Malaysia
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2018
Shops
selling bear
bile
products
2018
Shops not
selling bear
bile
products
Comparison of results in relation to proportion of TCM outlets selling/not selling bear bile products
for each State in Peninsular Malaysia between June 2017 and May 2018.
FIGURE 7
13 An update on the bear bile trade in Peninsular Malaysia

14
An update on the bear bile trade in Peninsular Malaysia
DISCUSSION
AND CONCLUSIONS

15 An update on the bear bile trade in Peninsular Malaysia
Malaysia is considered one of the remaining
strongholds for wild Sun Bear populations in Asia.
Despite all efforts to end the illegal bear trade
in Malaysia—ranging from providing evidence
for enforcement action, engaging the Ministry
of Health on registration of TCM products,
highlighting the plight and protection status of
bears in Malaysia to regular engagement with
the TCM community and raising awareness on
sustainable and herbal alternatives to bear bile,
bears are still being poached and killed for their
parts (Or et al., 2017; Gomez et al., in prep).
Overall, there seems to be little change in terms
of availability or types of products in markets
over the years. While the percentage of outlets
found selling products claiming to contain
some form of bear bile product has increased
since 2012, it has become less clear whether
retailers are selling genuine bear bile products
or are circumventing the law by claiming their
bear bile products only contain herbs and other
animal bile. Unfortunately such claims can
SRP] FI ZIVMƼIH XLVSYKL JSVIRWMG (2% XIWXMRK
Regardless, this study does reveal the nature of
the trade continuing in Malaysia. Although less
common, allegedly pure bear bile products like
gall bladders were also available, in violation of
national laws that prohibit trade in bears, their
parts and products. Further, reports of traders
importing pure bear bile from China, South
Korea and Indonesia is also a clear violation of
CITES and of Malaysia’s CITES-implementing
law, INTESA. While countries like China and
South Korea still permit bear farming for the
extraction of bile, the international commercial
trade in bear bile products is strictly prohibited
as all Asian bear species are listed in Appendix
I of CITES.
TRAFFIC’s engagement with the TCM
community appears to have made an impact on
one front: most if not all retailers were aware that
Sun Bear is a protected species and any trade in
parts or derivatives is prohibited by law. There
also appears to be fewer TCM practitioners
who were openly trading in whole gall bladders.
That said, the fact that more retailers are aware
of the law could also mean the trade in bears,
their parts and derivatives has become more
discreet. This uncertainty is a concern that
requires deeper investigation.
According to Lee et al., (2015), staff in 53%
of the shops surveyed openly acknowledged
being aware that trade in bears and their parts
was illegal, with one trader even claiming that
he continued to do so as the risks associated
with selling prohibited products allowed him to
charge a higher price. Lee et al., (2015) also noted
how TCM retailers were adept at circumventing
the law i.e. bear bile products were kept hidden
and there was a lack of or mislabelling of
products, which also extended to the ingredient
list of products. During the current survey there
were retailers who were reluctant to deal with
the researchers, and on occasion were even
aggressive when asked about the availability of
bear bile products. Several TCM retailers also
revealed that they were only willing to sell bear
bile products to regular customers or people
introduced by their regular customers. However,
it is unclear if retailers continue to push these
products due to consumer demand for bear bile,
or because bear products fetch a higher price
than other herbal or alternative remedies.
Nevertheless, the legal prohibition to trade in bear
parts and the increase in awareness among TCM
retailers now means that it has become more
HMƾGYPXXSQSRMXSVXLIMPPIKEPREXYVISJXLIXVEHI
Any measure taken to reduce the exploitation
of Sun Bears is ineffective without stronger law
IRJSVGIQIRX EGXMSR WTIGMƼGEPP] XS QSZI JVSQ
arrests and seizures through to prosecution
and convictions. There have been 29 cases
related to TCM offences in Peninsular Malaysia
between 2012 and 2015. More resources need
to be concentrated on law enforcement efforts,
which increasingly require in-depth monitoring

16
An update on the bear bile trade in Peninsular Malaysia
and proactive investigation of the individuals
involved, from hunters, to middlemen, to traders,
and consumers. Checks on TCM shops should
continue to be conducted periodically and should
include forensic DNA tests on bear bile products
to verify if they do indeed contain bear parts or
products. The Health Ministry and the National
Pharmaceutical Control Bureau should conduct
more rigorous scrutiny of TCM products being
imported/licensed, particularly those containing
or claiming to contain wildlife products.
Continued engagement with the TCM industry,
particularly through the FCPMDAM, will be
crucial in ensuring that the industry can self-
police and be a voice for wildlife conservation.
This can be done in partnership with non-
governmental organisations, research
institutions and government agencies based
on continued monitoring of outlets, provision
of materials to raise awareness and promoting
alternatives to bear bile. Furthermore, the
degree to which consumers knowingly or
unwittingly contribute to bear part demand has
yet to be addressed in Malaysia. A preliminary
survey to understand public attitudes and
awareness of bear bile trade in Malaysia in
2013, commissioned by TRAFFIC, found that
most respondents had limited knowledge and
many misconceptions about the conservation
implications and illegal nature of the bear bile
trade. More detailed evidence-based research
is needed to understand consumer behaviour
better and would be critical in determining
any behaviour change approaches to reduce
demand for bear bile products. Related actions
to encourage legal and responsible purchasing
of TCM products that contain wildlife should
also be considered.

17 An update on the bear bile trade in Peninsular Malaysia
Burgess, E.A., S.S. Stoner and K.E. Foley. (2014). Brought to bear: An analysis of seizures across
Asia (2000–2011)86%**-'4IXEPMRK.E]E7IPERKSV1EPE]WME
*SPI]/)'.7XIRKIPERH'67LITLIVH4MPPWTS[HIVWZMEPWERHƽEOIW8LIFIEVFMPI
trade in Asia86%**-'4IXEPMRK.E]E7IPERKSV1EPE]WME
Gomez, L. (2017). Alternatively Effective: a conference on substitutes to bear bile in traditional
Chinese medicine in Malaysia. TRAFFIC Bulletin, Vol.29, No.2.
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techsavvy-youth-the-biggest-players-in-illegal-wildlife-trade/
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Malaysia. TRAFFIC Bulletin, Vol. 26, No. 1, pp: 37-40.
Krishnasamy, K. and S. Stoner. (2016). 8VEHMRK*EGIW%6ETMH%WWIWWQIRXSRXLIYWISJ*EGIFSSO
to Trade Wildlife in Peninsular Malaysia. 86%**-'4IXEPMRK.E]E7IPERKSV1EPE]WME
Lee, S.L., E.A. Burgess, and S.C.L. Chng. (2015). Hard to bear: An assessment of trade in bear bile
and gall bladder in Malaysia. 86%**-'4IXEPMRK.E]E7IPERKSV1EPE]WME
Meijard, E. (1999). Human imposed threats to Sun bears in Borneo. Ursus, Vol. 11, pp: 185-192.
1MPPW.ERH'7IVZLIIRThe Asian Trade in Bears and Bear Parts. TRAFFIC USA.
Or, O.C., L. Gomez and C.F. Lau. (2017). Recent Reports of Sun Bear Seizures and Poaching in
Malaysia. International Bear News, Summer 2017, Vol.26, No.2.
4IVIMVE(60SLERH1&&SRƼKPMSThe Bear Trade in Malaysia: the bear gall bladder and
bear bile trade in Traditional Chinese Medicine shops in Malaysia, WPSA, UK.
Shepherd, C.R. (2006). Bear Trade in Southeast Asia: the status of protection for Southeast Asia’s
bears. In: Williamson, D.F. (Ed). 2007. Proceedings of the Fourth International Symposium
on Trade of Bear Parts3GXSFIV2EKERS.ETER86%**-')EWX%WME.ETER8SO]S
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TRAFFIC. (2016). No let-up in Asia’s bear trade. TRAFFIC Press Release. 25 October:
 LXXTW[[[XVEƾGSVKRI[WRSPIXYTMREWMEWFIEVXVEHI
REFERENCES

18
An update on the bear bile trade in Peninsular Malaysia
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19 An update on the bear bile trade in Peninsular Malaysia
SEPTEMBER 2019
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