Giraffes, hippos, & polar bears are in trophy hunting demand. Pangolin demand is believed to come chiefly from China.
WASHINGTON D.C.––The U.S. Fish & Wildlife Service on June 17, 2025 formally proposed in the Federal Register to protect pangolins under the Endangered Species Act.
Pangolins are the first vertebrate species to be proposed for an Endangered Species Act listing since the January 2025 inauguration of U.S. president Donald Trump.
Because pangolins are not native to the U.S., listing them as endangered does not oblige the U.S. Fish & Wildlife Service to do anything to protect pangolin habitat.
Because pangolins are believed to be poached and trafficked mainly for their scales, an ingredient in some traditional Chinese medicines, a U.S. Endangered Species Act listing for pangolins would embarrass China.
“World’s most heavily trafficked mammal”
Believed to be “the world’s most heavily trafficked mammal,” Fish & Wildlife Service media contact Christine Schuldheisz explained a day earlier, “pangolins are small, nocturnal mammals,” resembling tree-dwelling armadillos, “covered in tough, protective keratin scales,” who “use their long, sticky tongues to eat ants, termites and other insects.
“Pangolins have a single pup annually and live in a variety of habitats, including savannas, woodlands, and forests,” Schuldheisz said in a media release.
The proposed Endangered Species Act listing of pangolins prompted immediate questions, not because there seems to be any serious doubt that pangolins are endangered worldwide, but because the move “comes despite Trump’s efforts to weaken the act, aligning with ongoing conservative criticism that it stifles economic growth,” summarized Alexa St. John for The Independent.
Endangered listing for giraffes on hold
On November 20, 2024, for instance, Schuldheisz announced that “The U.S. Fish and Wildlife Service is proposing federal protections for several giraffe species.
“After reviewing the best available scientific and commercial information,” Schuldheisz said, “the Service proposes listing all three subspecies of northern giraffe from west, central and east Africa as endangered under the Endangered Species Act. The Service also proposes listing two giraffe species from east Africa as threatened.”
That proposal was immediately opposed by trophy hunters, an affluent and influential Trump constituency. One hundred twenty days after the 90-day public comment period on the giraffe listings expired, which should have allowed the listings to go into effect, the giraffe listing proposal remains pending.

Arctic foxes, polar bears, and Antarctic penguins are also hard-hit by global warming. (Beth Clifton collage)
What about polar bears?
“Polar bears, as well as penguins, not found in the U.S., have also been in discussions for listing over the years,” St. John mentioned, but “Trump’s executive order declaring an ‘energy emergency’ in the U.S. says the Endangered Species Act can’t stand in the way of energy development, signaling that protections could be rolled back.”
Polar bears, like giraffes, are coveted by trophy hunters. Polar bears also inhabit––among other places––parts of the Arctic National Wildlife Refuge.
Although two previous offers of oil drilling leases within the Arctic National Wildlife Refuge drew no interest from major oil companies, Interior Secretary Doug Burgum on March 20, 2025 announced that the entire coastal plain portion of the refuge is to be opened to drilling leases.
Burgum, added Dino Grandoni of the Washington Post, “has previously said the endangered list is too long and is an ineffective way of conserving many species.”
Pangolin listing also long delayed
“The slowness to list pangolins, however, preceded this administration,” Grandoni noted. “Environmental groups petitioned the government to list the pangolins a decade ago.”
Pangolins may not have been previously listed under both the first Trump administration and under the Joe Biden administration as a political concession to China. Pangolins may now be proposed for an Endangered Species Act listing simply as a continuation of the present Trump administration trade wars with China.
China has long been perceived as the major destination of poached and illegally trafficked pangolin scales, though some very recent research, in combination with Chinese government actions, suggests this may no longer be true.
The federal pangolin listing proposal
“In response to declining pangolin populations caused by illegal wildlife tracking, habitat loss and poor genetic health, the U.S. Fish & Wildlife Service is proposing to list seven species of pangolin as endangered species under the Endangered Species Act,” Schuldheisz said in a media release.
“The four Asian species proposed for listing are Chinese, Indian, Sunda, and Philippine. The three African species are white-bellied, black-bellied, and giant.
“One of the main threats to pangolins is wildlife trafficking, a crisis that includes the poaching, smuggling and illegal trade of endangered species,” Schuldheisz continued.
“Pangolins are particularly vulnerable to wildlife trafficking due to their slow and peaceful demeanor,” Schuldheisz explained. “With limited defenses beyond their scaly exteriors, they often roll into a ball when threatened.
“Heavily targeted by criminal organizations”
“Pangolins are heavily targeted by poachers and criminal organizations. The proceeds from the illicit sale of pangolins and other imperiled species often fund serious crimes, including drug and arms trafficking.
“Pangolins are currently protected under the Convention on International Trade in Endangered Species of Wild Fauna & Flora [CITES],” Schuldheisz added.
“International trade of this species is permitted only under exceptional circumstances, and international trade for commercial purposes is prohibited,” which makes the U.S. Endangered Species Act listing somewhat redundant.
60-day comment period
The Federal Register publication of the proposal to list pangolins as endangered opened a 60-day public comment period.
The U.S. Fish & Wildlife Service “will review and consider all comments received by August 18, 2025, before publishing a final rule. Please go to www.regulations.gov, docket number FWS-HQ-ES-2025-0028,” Schuldheisz concluded.
“Case is urgent”
“The case for protecting pangolins is not merely strong; it’s urgent,” responded Humane World for Animals president Kitty Block and Humane World for Animals Action Fund president Sara Amundson in a joint blog posting.
“In 2016,” Block and Amundson recalled, “our delegation to CITES worked to secure the support of 183 member nations to give the highest level of protection to all eight pangolin species, banning the international commercial trade in pangolin parts.
“We have organized public awareness campaigns to reduce demand for pangolin parts in China and Viet Nam and supported the rescue and rehabilitation of pangolins in South Africa,” Block and Amundson said.
Chinese demand for pangolin scales, used in traditional medicines, was at that time almost universally believed to be the major cause of pangolin poaching worldwide.
Pangolin poaching in India
Reported Shubhobroto Ghosh, wildlife research manager at World Animal Protection, on December 13, 2023, “A review of pangolin seizure incidents in India between 1991 and 2022 has put the focus back on the continuing illegal trade of the species.
“The analysis by World Animal Protection, Monitor Conservation Research Society, Oxford Wildlife Trade Research Group, Wildlife Protection Society of India and Wildlife Conservation Research Unit of Oxford University collated 426 seizures involving an estimated 8,603 pangolins.
“Investigations by the Wildlife Protection Society of India indicate that the escalating poaching and trade in live pangolins is led by market demands from outside India.
“Wildlife crime enforcement efforts in India were undermined by low prosecution rates, as only 1.4% of recorded pangolin seizures resulted in successful convictions.”
Traffickers turned to Africa
As pangolins became scarce in Asia, traffickers turned toward Africa.
The Dutch organization Wildlife Justice Commission reported that 17% of the pangolins and pangolin scales confiscated in 52 seizures by U.S. authorities between 2016 and 2019 came from a single African nation, the war-torn Democratic Republic of Congo.
But pangolin population surveillance begun in 2018 at 44-square-mile Yangmingshan National Park, the largest of the nine Taiwanese national parks, found that dog attacks rather than poaching accounted for more than half of all documented injuries to pangolins.
China pledged to fight the traffic
In November 2021, reported Boris Ngounou for the African Elephant Journal, the 7th Forum for China-Africa Cooperation, held in Dakar, Senegal, resolved that “Africa and China will strengthen their cooperation in wildlife protection and support the improvement of the conservation capacity of African countries,” including “to raise public awareness and jointly combat illegal wildlife trade,” by “establishing an anti-smuggling cooperation mechanism to crack down on crimes of smuggling endangered species and their products.”
Trafficking in elephant tusk ivory and pangolin scales were mentioned as subjects of special concern.
World Animal Protection in April 2025 reported that “China has removed Guilingji, a traditional medicine containing pangolin ingredients, from the upcoming 2025 edition of the Pharmacopoeia of the People’s Republic of China.
China delisted pangolin scale medicine
“Guilingji is not just any traditional remedy,” World Animal Protection explained. “It has held a prominent place in Chinese medicine since it was classified as a first-level national secret prescription in 1957.
“Delisting it from the pharmacopoeia suggests a shift in regulatory priorities, especially as pangolins are now protected under the highest level of international and domestic conservation laws.
“While this does not constitute a ban on Guilingji’s sale or production, the removal makes it harder to promote and prescribe.
“The Chinese Pharmacopoeia is the official standard for clinical prescriptions,” World Animal Protection added. “If a medicine is no longer listed, it indicates that it no longer meets criteria for safety, efficacy, or ethical acceptability, and healthcare providers may reduce or avoid its use altogether.”
Study finds pangolins are poached more for meat than scales
Cambridge University Department of Zoology Ph.D. candidate Charles Emogor meanwhile won his doctorate with a study published in the June 13, 2025 edition of the journal Nature Ecology & Evolution, citing ten co-authors, finding that “Pangolin hunting in southeast Nigeria is motivated more by local meat consumption than international demand for scales.
“Using data collected from questionnaires distributed to 809 hunters and meat vendors in Nigeria, the world’s biggest hub for pangolin trafficking,” Emogor et al learned, “97% of pangolins are captured opportunistically or during general hunting, with 98% of these caught for meat and mostly either eaten by hunters (71%) or traded locally (27%).
“Meanwhile, around 70% of scales are discarded, with less than 30% sold,” Emogor et al wrote. “In addition, local [pangolin] meat prices are three to four times higher than those for scales.
Estimates of pangolin loss based on scale traffic may be far low
“Since most pangolin scales are discarded,” Emogor et al concluded, “relying on data on the trade in scales to assess the species’ conservation status is likely to vastly underestimate pangolin exploitation.”
Further, Emogor et al suggested, “Law enforcement efforts targeting traffickers are unlikely to reduce pangolin hunting substantially,” at least “in this part of Africa. Instead, priority should be given to site-level interventions, such as anti-poaching patrols and community-based actions, including initiatives to improve food security and behavior change programs for hunters.”
No action on hippo listing
Also long nominated for Endangered Species Act protection, but not yet proposed for protection by the U.S. Fish & Wildlife Service, is the common hippopotamus, sharing much African habitat with giraffes and pangolins, but also in trophy hunting demand.
Summarized The Wildlife Society on February 14, 2025, “Several conservation groups petitioned the Fish & Wildlife Service to add the common hippopotamus (Hippopotamus amphibius) to the U.S. Endangered Species Act in 2022 due to the trade of its parts in the U.S. for meat, leather and other products.
“As a result of poaching in Africa and other issues, hippos are declining in many parts of their historical range. A federal judge has now ordered the USFWS to decide about listing hippos by July 27, 2028,” in effect postponing any significant action until near the scheduled end of the Trump administration.
Fish & Wildlife Service missed deadline
Elaborated Dinah Voyles Pulver for USA Today, “Wild hippos are declining in number and are considered vulnerable to international trade in hippo parts, including the sale of their teeth, skulls, ivory, skin and meat, wildlife conservation groups say. They argue that adding the common hippo to the endangered list would help curb the trade of its parts in the U.S., which continues unchecked.
“In 2022, U.S. Fish & Wildlife Service scientists said the evidence showed [an Endangered Species Act] listing might be needed. However, the agency missed a 12-month deadline to act on the decision, prompting affiliates of the Humane Society of the United States [now Humane World for Animals] and the Center for Biological Diversity to sue in 2024, saying the agency was moving too slowly.”
A recent study by Hannah Lacy at the University of Leeds in the United Kingdom and two co-authors found that “Across their range, hippos may be declining at 6% to 8% a year,” Pulver summarized, with estimates of surviving hippo populations across Africa ranging “from 115,000 to 192,000 over the past decade.”
“The U.S. is the primary driver of demand for hippo products, responsible for nearly half of global imports between 2019 and 2021,” Pulver wrote. “At least 3,081 hippos were killed to meet U.S. demand between 2009 and 2018,” according to the organizations petitioning for hippos to receive Endangered Species Act protection.
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