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T R A F F I C OPTIONOPTIOND COVER
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Option D cover subtitle 2 lines subtitle subtitles subtitlesIn
mainland China, Hong Kong and Taiwan
subtitles

JUNE
2016
MONTH
2016

Authors,Wu
authors, authors, authors, authors, authors, authors, authors
Joyce

TRAFFIC REPORTTRAFFIC, the wild­life trade monitoringnet­work, is the leading non-governmentalorganization working globally on trade inwild animals and plants in the context of bothbiodiversity conservation and sustainable
development. TRAFFIC is a strategic allianceof WWF and IUCN.
Reprod­uction of material appearing in thisreport requires written­permission fromthe publisher.
The designations of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of TRAFFIC
or its supporting ­organizations con­cern­ing
the legal status of any country, territory, or
area, or of its authorities, or concerning thedelimitation of its frontiers or boundaries.
The views of the authors expressed in thispublication are those of the writers and do notnecessarily reflect those of TRAFFIC, WWF
or IUCN.
Published by TRAFFIC

Taipei Office 3F.
No. 92, Ln 106, Sec. 3,
Bade Road, Songshan District,Taipei City 105, Taiwan© TRAFFIC 2016. Copyright of material
published in this report is vested in TRAFFIC.
ISBN no:UK Registered Charity No. 1076722
Suggested citation: Wu, J. (2016). Shark fin
and Mobulid Ray gill plate trade - In mainland
China, Hong Kong and Taiwan. TRAFFIC,
Cambridge UK
Front cover photograph: Seafood shop(s) in
Hong Kong
Photo credit: Joyce Wu

SHARK FIN AND MOBULID RAY GILL
PLATE TRADE
In mainland China, Hong Kong and Taiwan© JOYCE WU / TRAFFIC

Joyce Wu

Seafood shop(s) in Hong Kong

This report was published with the kind support of© JOYCE WU / TRAFFIC

Shark fins with skin

TABLE OF CONTENTS

Abbreviations and Acronyms used in the report ............................................ iii
Acknowledgements ............................................................................................ iv
Executive Summary ............................................................................................ v
Background and Introduction ........................................................................... 1
Methodology ....................................................................................................... 3
Results .................................................................................................................. 8
CITES trade data ........................................................................................ 8
FAO FishStatJ trade data ........................................................................... 11
Customs trade data .................................................................................... 13
Mainland China’s shark fin imports and (re)exports......................... 13
Taiwan’s shark fin imports and (re)exports ........................................ 17
Hong Kong’s shark fin imports and (re)exports ................................ 21
Online survey ............................................................................................. 33
Market survey ............................................................................................. 38
Shark fins ................................................................................................ 38
Mobulid ray gill plates ........................................................................... 50
Discussion and Comments ................................................................................ 52
Recommendations .............................................................................................. 64
References ............................................................................................................ 67
Annex ................................................................................................................... 71

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwanii

ABBREVIATIONS AND ACRONYMS USED IN THE REPORT
AFCD

Agriculture, Fisheries and Conservation Department, CITES Management
Authority in Hong Kong Special Administrative Region (SAR)

BOFT

Bureau of Foreign Trade, Taiwan, compatible CITES Management Authority in
Taiwan.

CITESConvention on International Trade in Endangered Species of Wild Fauna andFlora

China CITES MA The Endangered Species Import and Export Management Office, CITESManagement Authority in People’s Republic of China.
CNY

Chinese Yuan

CSD

Census and Statistics Department, which keeps import and export data for the
Hong Kong SAR

FAO

Food and Agriculture Organization of the United Nations

NDF

Non-detriment Findings

IUCN

International Union for the Conservation of Nature

TRAFFIC

The Wildlife Trade Monitoring Network, a strategic alliance of IUCN and WWF

UNEP-WCMCWorld Conservation Monitoring Centre, United Nations Environment
Programme

USD

United States Dollar

WCPFC

Western and Central Pacific Fisheries Commission

iii TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

ACKNOWLEDGEMENTS
This report was made possible with financial support from an anonymous donor, while the Wildlife
Conservation Society (WCS) helped support the administration of the grant.
Many people provided support to this report. The author would like to express thanks to all those who
helped to make this report possible by providing advice as well as sharing their knowledge on thesubject.
The author gratefully acknowledges the Agriculture, Fisheries and Conservation Department, Hong
Kong SAR, Stan Shea from Bloom Association in Hong Kong, and many traders and shopkeepers inmainland China, Hong Kong and Taiwan for providing information. The author would also like tothank Yu Xiao and Ling Xu from TRAFFIC for their help with the market survey and data collection,
as well as Andy Cornish from WWF International and Erika Reuter from WCS for their review of thedraft report.
The author would especially like to thank the reviewers from TRAFFIC: Glenn Sant, Yannick Kuehl,
Richard Thomas, Julie Gray, Wilson Lau, Ling Xu and Fei Zhou for their comments and advice on
improving draft versions of this report, as well as Sean Lam and Rita Chang for their great support.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan iv

EXECUTIVE SUMMARY
Despite shark fin being a “traditional” Chinese product, the trade and marketing of it (and to alesser extent manta gill plates) changes rapidly depending on where and how profits can be made.
Almost every aspect that the research has looked at is dynamic in a way that would have beendifficult to predict from the first study (Clarke 2004) ten years or so ago.
Mainland China, Hong Kong and Taiwan have had a long and varied history in the trade of shark
fins.

Together they account for more than 90% and 70% of the global import and (re)export,

respectively, between 2005 and 2011, based on FAO import data1.

Recent declines in the global

2

trade have also been reflected in the import and (re)export of shark fin from these three countries
and territories.

However, possible illegal shark fin trade could indicate that the trade decline of

mainland China, Hong Kong and Taiwan may not be as substantial as the official data haverecorded.

Given the lack of knowledge about the scale of under-reporting in mainland China, it ispossible that the extent of the decline may be much lower than available data suggest.

This reporttakes a comprehensive look at how the shark fin trade is changing in the three study areas, andprovides recommendations to stakeholders to improve compliance with the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES) and increase
traceability of the trade in shark fins and mobulid ray gill plates.

CITES trade
Based on the CITES species trade data between 2003 and 2013 (Annex 1), global reported shark fin
imports and (re)exports were 7,720.7 kg and 1,495.6 kg, respectively.

During this period, Hong

Kong reportedly accounted for 90% of global reported CITES shark fin imports. This is largely
explained by Hong Kong’s import of 6,933.4 kg of Basking Shark Cetorhinus maximus fins from
Norway during 2005, 2008, 2009 and 2102, with only 9 kg of this re-exported to Malaysia in 2006.
The next largest importer was Spain, which only reported 602 kg of Porbeagle Shark fin Lamna
nasus imports during the same period, which pales in comparison to Hong Kong’s record on
CITES-listed shark fin trade.

Singapore, the other important global hub for the shark fin trade,

only reported 68 kg of shark fin (Basking Shark) imports in the same period.
Hong Kong’s dominance of CITES-listed shark fin trade is not surprising considering it handled
50% of the global shark fin trade (Clarke 2004), and imports shark fin from more than 100 countries

1
2

FAO FishStatJ March 2015. http://www.fao.org/fishery/statistics/software/fishstatj/en(re)export included export and re‐export

v TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

and territories.

Hong Kong re-exports around 50% of its imported shark fin, with more than 60%of this going to mainland China.
As one of the top five shark catchers globally, 70% of Taiwan’s shark fin export was to Hong Kong
between 2005 and 2014.

Taiwan has been identified as one of the hotspots for some of the world’s

most threatened shark species (Brautigam et. al. 2015).

However, surprisingly there is no record ofexports from Taiwan to Hong Kong of CITES-listed shark fin species.

Customs trade
Overall there are significant declines in the shark fin trade recorded in all three countries andterritories based on the officially recorded Customs data.

A reduction in shark fin imports and(re)exports began to appear in 2005, and was especially pronounced from 2009 onwards.

Hong

Kong and Taiwan’s decline in shark fin trade was moderate in comparison with mainland China.
Hong Kong’s imports and Taiwan’s exports of shark fin were both stable between 2005 and 2011,
but dropped significantly in 2012 and 2013, and remained at low levels in 2014.

Trade between

Hong Kong and mainland China followed a similar pattern.
Between 2005 and 2014, around 86% of the shark fin that Taiwan exported went to Hong Kong
(70%, 5,269 t) and mainland China (16%, 1,209 t).

However, the annual export of shark fin from

Taiwan to Hong Kong and mainland China followed similar declines in the most recent years, from2012 to 2014.

Exports to mainland China were especially low, dropping to less than 26 t in 2013

and 15 t in 2014.
Hong Kong’s shark fin (re)exports to mainland China started decreasing in 2005, and dropped
significantly in 2010.

The (re)export trade from Hong Kong, however, has been somewhat offset

by increases in trade with Viet Nam.

Viet Nam has since become Hong Kong’s largest shark finexporting receiver during 2010, 2013 and 2014.
down in the latter years.

This trade reached a peak in 2010, but has slowed

Likewise, Viet Nam has replaced mainland China as the largest importerof Hong Kong’s sea cucumber (re)export since 2004 (To and Shea 2012).

It is possible that Viet

Nam is not the final place of consumption or processing destination, but could instead be used as atransit point for re-routing wildlife products, e.g. to mainland China.
The Customs records of mainland China, Hong Kong and Taiwan for the shark fin trade are notrecorded in coding systems that are easily compared.

Taiwan uses 11-digit Custom codes for fivedifferent shark fin commodities. Hong Kong and mainland China both use an eight-digit Customs
code system, shark fin in mainland China is considered as one commodity and aggregated into a

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan visingle Customs category, while Hong Kong separates raw and processed shark fin into five different
shark fin commodities.

Due to these differences, the total (gross) annual import and (re)export

volumes of shark fin, without separating different commodities, from mainland China, Hong Kong
and Taiwan were used for comparison.
The import and (re)export data comparison reveals that Hong Kong’s system of capturing trade
data is more thorough than those used by mainland China and Taiwan.

Hong Kong reported

higher volumes of trade with Taiwan, regardless of imports and (re)exports (Annex 6).
differences were especially large for trade from Hong Kong to Taiwan.

The

This may be because of

Taiwan’s import tariff, which provides less incentive to report accurately compared with Hong
Kong, which is a free trade port.
A similar pattern was also found for the trade between Hong Kong and mainland China.

Hong

Kong reported much higher export volumes (around 46 times that of mainland China’s reported
import volume) to mainland China.

However, Hong Kong reported fewer imports from mainland

China than were recorded by the China Customs as being exported to Hong Kong from mainland
China.
A major crackdown on the shark fin industry was taken in mainland China at the end of 2012
because of the violation of import tariff regulations (Anon., 2014d).

This case indicated that someshark fins (re)exported from Hong Kong to Viet Nam eventually entered mainland China.

Online markets
Only a limited amount of shark fin advertisements and sellers were detected due to the “No shark
fin sales” policies of several e-commerce platforms.

Some shark fin e-commerce stores were foundon business to business (B2B) websites which had the ability to handle large inventories of shark fin
and shipments.

There were more advertisements of mobulid ray gill plates found on websites

which may be due to a lack of related restrictive policies of the e-commerce platforms for thisproduct, recognizing shark fin is on the prohibition list.

However, most of the advertisements andsellers of mobulid ray gill plates were on consumer to consumer (C2C) e-commerce websites.

The

sellers and consumers of mobulid ray gill plates tend to deal in small amounts of product at any one
time.

Most mobulid ray e-commerce shops were located in southern China and sellers in Hong

Kong are likely to be serving the southern China market as well.
shops are located along the whole coast of mainland China.

In contrast, shark fin e-commerce

In total, 85% of all e-commerce shopswith identified locations are situated near or south of Shanghai; 79% of those shops are found in
Guangdong Province.

vii TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

An earlier survey found that Guangzhou was the centre for mobulid ray gill plates trade (Heinrichs
et al. 2011).

Based on the geographic distribution of e-commerce shops, it appears as though themarket for mobulid ray gill plates is limited to four coastal provinces in southern China, especiallyin Guangdong, and most likely consumed by households as a tonic, as opposed to being consumed
in restaurants and hotels.

Shark fin consumption is still relatively robust along the coastal cities,

and may start to expand to inner cities along the Yangtze River.

Of the 144 e-commerce shopswith known locations, 140 were located in the coastal provinces in mainland China from northeast
to southeast China, with the other four shops located in inner provinces: Shenyang of Liaoning,
Datong of Shanxi, Wuhan of Hubei and Chengdu of Sichuan (Figure 13).

Physical market
This survey showed that shark fins are still commonly available in mainland China, Hong Kong andTaiwan, even with rising levels of awareness about the unsustainable exploitation of sharks globallyand the government of mainland China’s No Shark Fins policy3.

Most of the premises that sellshark fin also offer other products, such as dried seafood and high-priced Chinese medicines.

The

shark fin premises in Guangzhou/Shenzhen and Hong Kong provided a higher variety of shark fin
categories4, on average 3.3 and 3.4 shark fin categories respectively, than stores in Beijing/Shanghai(3) and Taiwan (2.5).

Shark fins accounted for a higher percentage of the goods sold withinpremises in mainland China (34% in Beijing/Shanghai and 39% in Guangzhou/Shenzhen) thanthose in Hong Kong (18%) and Taiwan (21%).

These dried food stores in Hong Kong and Taiwan

are therefore less reliant on selling shark fins for their income.

In general, prices for shark finswere higher in Taiwan and Hong Kong than in mainland China.
Based on the responses from shopkeepers, the fins available in Taiwan and Hong Kong are mainly
from locally processed sources, 81% and 76% respectively.
processing factories, especially in Hong Kong.

The figures seem higher for the existingThis may result from the fact that part of theprocessing, such as drying, is conducted in Hong Kong.

In contrast, 37% and 14% of shark fin

types found in Beijing/Shanghai were processed in Guangdong and Hong Kong, respectively.

Only

3% of shark fin categories offered in Guangzhou/Shenzhen were processed in Guangdong, 3% were
processed in other locations in mainland China, and none were processed in Hong Kong or Taiwan.

3

The general policy for official receptions, the purpose of which is anti‐corruption, was launched at the endof 2012, when Xi Jinping took the position as the president of China. A more detailed policy came out in
December 2013 to ban official expenditure on shark fins, birds’ nests and protected wildlife products.
4“Category” of shark fins refers to the different shark fin products available in the shops. It is not equal tospecies of shark, but is instead a combination of species, fin position and even quality or size of shark fin.
Some frequently available categories included Jin Shan, Yan Jian, Hai Hu and Gou (caudal).

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan viii

Sixty-seven percent of shark fin categories sold in Taiwan were primarily sourced in Taiwan (asopposed to “imported”).

In contrast, only a limited proportion of shark fin categories available in

Beijing/Shanghai (4%) and Guangzhou/Shenzhen (6%) were sourced in China.

At the same time,

only 11% of shark fin categories found in Beijing/Shanghai and 2% of those found in Taiwan were
imported from Hong Kong.

Only 1% of shark fin categories found in Hong Kong were claimed to

be imported from Taiwan.
Jin Shan Fin5 was the most commonly reported shark fin type by interviewees in Hong Kong (83%of surveyed shops) and Beijing/Shanghai (77% of surveyed shops).

A common trade route for thistype of shark fin is for it to be imported, or to have transited from San Francisco, USA, regardless ofthe species.

In Beijing/Shanghai, 20%, of shark fin categories were claimed to be imported fromthe USA.

In Hong Kong, the main importing countries were the USA (27%), Mexico (16%) and

Latin America (30%) (according to the shopkeepers).

However, the high visibility of Jin Shan Fins

in stores and the shopkeepers’ claim of origin of these products do not match with import data kept
by Customs in both mainland China and Hong Kong.

Imports from the USA for shark fins to

mainland China is equal to 1,060 t, or only 9% of the trade6, while for Hong Kong it is 16,659 t, or
19% of the trade7.
In general, shopkeepers did not have knowledge of the corresponding species for 85% of shark fin
categories; this percentage was especially high in Beijing/Shanghai (94%).

Shopkeepers in

Beijing/Shanghai and Hong Kong only identified shark fin categories of one (Blue Shark) and two
species (Tiger Shark and Blue Shark), respectively.

Shopkeepers in Guangzhou/Shenzhen

identified shark fin categories of four species (Tiger Shark, Silky Shark, Ocean Whitetip Shark andBlue Shark).

Shopkeepers in Taiwan identified shark fin categories to three species and one genus(Blue Shark, Silky Shark, Ocean Whitetip Shark and Guitarfish).

The species information claimedby the shopkeepers does not reflect the full breadth of shark species in the trade, as conveyed
through trade data. It is not known how accurate shopkeepers are in their claims about the species
being sold, but may be a reflection of the indifference of the market to the specificity of the product,that some shark species can replace another within the shark fin trade.

While Clarke et al. found

14 species from 40% of auctioned shark fins, in terms of weight, in Hong Kong in early 2000 (Clarke
5

Jin Shan Fin (Gold Mountain Fin) is the Chinese name given to shark fins that were traditionally sourced
from the USA and Latin America and imported/transited via San Francisco (Lin, 2010), which is called “OldGold Mountain” in the Chinese language, because of its gold mining history. Jin Shan Fins are valued highly
in shark fin markets due to their high quality. The sanitary requirements are considered superior in theUSA, therefore only shark fin, frozen and dried, which met the sanitary requirements of the USA enters San
Francisco. As a result, Jin Shan Fins which are transited or (re)exported from San Francisco have become asymbol of good quality.
6
0.12% (14 t) from the USA, 0.38% (44 t) from Canada, and 8.55% (1,002 t) from Latin America
7
0.7% from Canada, 2.3% from the USA and 16% from Latin America countries.

ix TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

et al., 2006), the difference may be due to Clarke’s findings being based on trader interviews andthis report’s findings being based on interviews with retail outlets.
Similar to online markets, the physical markets that offer mobulid ray gill plates for sale were moreconcentrated in southern China.

Of the markets that sold mobulid ray gill plates in Hong Kong,

their product diversity, price category and range were lower than those in Guangzhou andShenzhen.
The following recommendations are made in relation to shark fins and mobulid ray gill plates,
which are relevant to stakeholders in mainland China, Hong Kong and Taiwan:
Hong Kong, as the largest shark fin trading hub, handling up to 40% of global shark fin tradefrom more than 100 countries/territories, as well as roughly 90% of imports in CITES-listed
species between 2003 and 2013, recorded in UNEP-WCMC’s CITES Trade Database.
However, large inconsistencies in the data exist between trade volume recorded by UNEPWCMC and those recorded by Hong Kong Customs and Excise Department (7 t compared to85.823 t during the 11 year period, respectively).

Hong Kong, as well as the top 20 shark fin(re)exporting countries/territories, should improve their monitoring and reporting of the
shark fin and manta ray gill plate trade to ensure it meets basic reporting requirements under
CITES.

This could include periodically examining the CITES as well as Customs data withtrade partners to identify the possible gaps.

To identify/label CITES shark fins and manta ray

gill plates separately from mixed species shipments to increase the accuracy of information
reporting and recording on the species and volume, as well as issuing appropriate CITES
documents for trade.


Mainland China and Taiwan should ensure that all sharks and rays harvested by and landed intheir jurisdictions are legally acquired, traded with the correct species name and withappropriate documents.

It is advised that a traceability system for CITES listed shark and ray

species could be developed and applied from harvest to the point of first export in all sharkand ray catching countries/territories.


The responsible CITES authorities in mainland China, Hong Kong and Taiwan should
enhance awareness of regulations on the shark fin and manta ray gill plate trade to otherrelevant authorities, such as Customs, quarantine and coastguard, in order to increase thedetection of illegal trade. Relevant trainings, including species and products identification,
should also be provided if necessary.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan xIncrease awareness of regulation and product identification among the shark fin and manta
ray gill plate trading and processing industries in mainland China, Hong Kong and Taiwan, toincrease the support and compliance to CITES by the shark fin industries. Productidentification and regulation awareness training should be provided to frontline officers if
necessary.

Register all merchants on the physical and e-commerce markets that are involved in the tradeof CITES-listed shark species, and require documented evidence of legal sourcing.



Increase the knowledge of shopkeepers and e-commerce companies on the CITES regulations,e-commerce policy and legal sourcing practices of shark fins and manta ray gill plates, as wellas the importance of correctly labelling information as to the species and origin of the fins andgill plates to enable informed consumer choice.

Monitor domestic markets and e-commerce websites to verify the legality of shark fins andmobulid ray gill plates available on the market, including the use of correct labelling of species
and origin of the products.



The relevant authorities in mainland China (China CITES MA), Hong Kong (AFCD) andTaiwan (BOFT) should improve the accuracy of their record keeping and reporting of the
trade of CITES-listed sharks and mobulid rays to the CITES Secretariat.

Introduce Customs codes in mainland China and Taiwan to distinguish between raw andprocessed, as well as dried and frozen shark fins, which would help to enhance trademonitoring.

Enhance the monitoring and patrolling of trade routes such as between Hong Kong and Viet
Nam (and possibly to other countries/territories, e.g. mainland China), especially in thedetection of illegal trade in shark fin and mobulid ray gill plates, as well as to research andquantify related trade levels and to develop target strategies to combat illegal trade.

Authorities in mainland China, Hong Kong and Taiwan should co-operate, including throughregular exchange and setting up a joint task force, in order to ensure the legality of trade inshark fin and mobulid ray gill plate.



Furthermore, the Customs and trade authorities in mainland China and Taiwan need to
examine the procedure of trade management and data recording to understand the reason for
their trade data reporting lower volumes than their trade partners.

This should help clarify

whether illegal trade is a component of the overall trade.


The relevant authorities, such as trade, commerce and fisheries, in mainland China, Hong
Kong and Taiwan should conduct regular inventories of shark fins and mobulid gill plates tounderstand the availability and consumption volume in their jurisdictions, and to verify if thevolume unreasonably exceeds the sum of imports and harvests.

Evidence-led consumer behaviour change approaches should be applied to reduce demand forshark fins and mobulid ray gill plates products in target markets.

xi TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan



Mainland China’s anti-corruption measures, including the ban of shark fin consumption in
official receptions, may have contributed to a decrease in consumption and consequently areduction of availability in the market. This example shows that government-led policy
interventions can contribute to decreased consumption and should be explored further.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan xii

BACKGROUND AND INTRODUCTION
The life history traits of sharks and rays, which are generally long-lived, mature late and have few
offspring, make them particularly vulnerable to over-exploitation.
critical role in ocean ecosystems.

As top predators, sharks play a

Marine sharks and rays are highly threatened, with populationsof many coastal and offshore species in serious decline.

According to a comprehensive 2014 study(Dulvy et al., 2014), around 25% of all sharks, rays and chimera species (Chondrichthyes) arethreatened with extinction due primarily to overfishing, whether targeted or incidental.
The 16th Conference of the Parties to CITES in 2013 resulted in the listing of seven species ofcommercially exploited shark species in Appendix II of CITES (Annex 1).

They are: Oceanic

Whitetip Shark Carcharhinus longimanus; Porbeagle Lamna nasus, three Hammerhead sharks
Sphyrna lewini, S. mokarran and S. zygaena, and manta rays Manta alfredi, M. birostris. The listingof the above species did not come into effect until September 2014, delayed by 18 months to enable
Parties to resolve the related technical and administrative issues.

Countries and territories have torecord the trade of CITES species according to their national regulations and report the records
annually to the CITES Secretariat.
CITES regulates international trade in threatened species, whether it involves live or deadspecimens or their parts and derivatives (CITES, 2016).

CITES includes species in three

Appendices, according to the degree of protection they need.
threatened with extinction.

Appendix I includes species

Trade in specimens of these species is permitted only in exceptional

circumstances. Appendix II includes species not necessarily threatened with extinction, but inwhich trade must be controlled in order to avoid utilization incompatible with their survival.
Appendix III includes species that are protected in at least one country, which has asked other
CITES Parties for assistance in controlling the trade (CITES, 2016).
The current overfishing of sharks is driven in large part by global trade of their highly-valued
products (Dulvy et al., 2014). These products include fins, meat, leather, liver oil and, cartilage; andin the case of manta/devil rays; gill plates.

Demand for shark fin is driven by the use of shark fin asa traditional delicacy and that for ray gill plates due to their use as a tonic medicine (Whitcraft et al.
2014).

Due to its high price, consumption of shark fins also denotes high social status.

In HongKong, for example, shark fin is most commonly consumed at wedding and birthday banquets(Anon., 2011a).

It is this aspect that has gained the most attention as a driving cause for shark

population declines.

1 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Mobulid Ray gill plate usage
Mobulid Rays (蝠鲼, 鱼彭鱼, 角鱼彭, 黑鱼彭, 角燕) are considered medicinal animals in the Chinese
Medicinal Animal Book, dating back to 1983 (Anon. ed., 1983).
Manta birostris were included under Mobulidae in the book.
Mobulid Ray are considered to be medicinal ingredients.

Two species, Mobula japonica and

The gill plate and brain of the

The gill plates of both species are

believed to have detoxification and anti-inflammatory functions and are used to treat exanthema.
They are also used to treat child measles and boils (Anon. ed., 1983).
According to advertisements on e-commerce websites, in addition to detoxification and antiinflammatory properties, mobulid ray gill plates also have anti-cancer and prolactin functions.
Many advertisements recommend putting mobulid ray gill plates into a stew with other common
ingredients for a couple of hours before drinking as a tonic to strengthen the body—a nontraditional medicinal use.

General shark fin processing procedures
Fresh or frozen fins go through various stages to end up with dried processed fins – which is thecommodity usually found in retail and wholesale dried food markets in mainland China, Hong
Kong and Taiwan.

These processing stages include drying, soaking in hot water, removing scales,

skins and bones, bleaching and drying for package (Mundy et al. 2015).
It is estimated that fresh shark fins lose around 75% of their weight after drying, and another 6570% after the removal of scales, skin, bone and meat (Anon. 2013a).
Shark fin processing factories started to move from Hong Kong to mainland China, such as
Jiangmen in Guangdong, from 1986 onwards (Kwong, 2013). Because of air and water pollution, theregulation relating to “offensive trades”8 was applied to shark fin processing in 1986 (Kwong, 2013).
This research is intended to increase understanding about the current market dynamics of shark
fins and mobulid ray gill plates in mainland China, Hong Kong and Taiwan, in order to improve
compliance with the Convention on International Trade in Endangered Species of Wild Fauna andFlora (CITES) and increase traceability of the trade in shark fins and mobulid ray gill plates.

A

current problem of shark and mobulid ray consumption is that most of the supply in the market are
unsustainable, untraceable and sometimes illegal.

8“Offensive trades” is a term related to polluting business activities. A Schedule of Offensive Trades was
declared based on Section 48 of the Public Health and Municipal Services Ordinance and Declaration of
Offensive Trades Notice. http://www.pland.gov.hk/pland_en/tech_doc/hkpsg/full/ch9/ch9_app_6‐2b.htm

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 2

METHODOLOGYCITES trade data9 on eight species and two genera of sharks and rays (Annex 1), from 2003 to 2013,
were accessed and downloaded from the CITES website on 15th October 201510.
records for the trade in ray species.

There were no

Four species of shark and one unspecified species of sawfish

were traded by mainland China, Hong Kong and Taiwan between 2003 and 2013.

The most recent

CITES shark and ray listings did not come into effect until September 2014 and hence informationon their trade would not be expected over this period of available data (Annex 1).

It is possiblethat some Parties have not yet reported their 2014 CITES trade data.
Records of shark fin trade data from mainland China, Hong Kong and Taiwan from 2005 to 2014
were purchased from mainland China’s Customs11, and obtained from Hong Kong’s Census andStatistics Department (CSD) and Taiwan’s Bureau of Foreign Trade, respectively.

As there were no

Customs codes specific to mobulid ray, mobulid ray gill plates or any fish gill plates in mainland
China, Hong Kong and Taiwan (Annex 2), no further analysis on mobulid ray gill plate trade wasconducted based on Customs data.

Hong Kong, but not mainland China or Taiwan, has clearly

separated exports from re-exports in the Customs data.

Therefore, in this analysis, the term“(re)export” is used to refer to the trade involving export and re-export.
Mainland China has only one Customs code to record shark fin product trade.
separate Customs code for different shark fin commodities.

There is no

The code was amended in 2012, tochange the description from “dried shark fin (Customs code 03055920)” to “shark fin (Customs
code 03057100)”.

Mainland China has two other Customs codes starting with 1604 forpreserved/prepared shark fin products.

Preserved/prepared products reported under 1604 areprocessed products, the recorded trade volume, in weight, may include other ingredients andpackages.

The trade data from these two codes were not included in this research to avoid any

double counting.

According to Dent and Clarke (2015), mainland China started to record thetrade of frozen shark fins from May 2000, but under the same code as frozen shark meat.

It istherefore not possible to estimate the share of frozen shark fin from the trade of frozen shark meatfor mainland China.

At the time of publishing this report, mainland China did not yet have a

specific Customs code for frozen shark fins.

9

CITES trade data from trading partners were used for Taiwan, which is not a Party to the Convention.
The CITES Trade Database was developed and is maintained by UNEP‐WCMC on behalf of the CITES
Secretariat, and can be accessed via the CITES website http://trade.cites.org/.
11
China Cuslink Company, Ltd
10

3 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Hong Kong also uses eight-digit Custom codes, but the coding system is not equivalent to mainland
China’s system.

Hong Kong has Customs codes for five different commodities of shark fins, which

are dried shark fin with cartilage, dried shark fin without cartilage, shark fin, salted shark fin withcartilage and salted shark fin without cartilage (Annex 2).

The Customs code for “shark fin”

(0305-7190) was created in 2012 to record trade for shark fin commodities not elsewhere specified
or indicated (NESOI).

Hong Kong Customs codes also separate raw and processed shark fins.

Hong Kong’s Customs data were obtained from the Census and Statistics Department (CSD), whichkeeps import and (re)export data for Hong Kong SAR.

According to Clarke (2002), shark fins withcartilage, commodity description in the Hong Kong Customs coding system, are considered raw andunprocessed material, and shark fin without cartilages are considered processed (with skin, cartilage
and meat removed).

Clarke (2002) also reported that the Customs code description of “shark finssalted or in brine, but not dried or smoked” actually covers “frozen” shark fins.

Hong Kongchanged some of its shark product codes in 2012, including the re-classification of wet shark fins as
frozen shark meat (Anon. 2014b).

To get around this for the purpose of analysis, the frozen sharkmeat code had to be adjusted for the years 2012 to 2014 in order to capture the proportion that is
salted (frozen) shark fin with cartilage (Eriksson and Clarke 2015).

Dent and Clarke (2015)

reported that HKCSD confirmed, in November 2013, that shark fin traders are advised to reportfrozen shark fins as frozen shark meat rather than as salted shark fins.

“Dogfish and other sharks,

frozen, excluding fillets, livers and roes” is the full description for frozen shark meat, which did not
exclude the “fins” and was the only shark related Customs code in Hong Kong with “frozen” in thecode description.

This may be the reason for HKCSD’s advice to traders.

However, Hong Kong

has reinstated separate commodity codes for frozen shark meat and frozen shark fins since January
2015 (Dent and Clarke, 2015).

Hong Kong also has two Customs codes starting with 1604 forpreserved/prepared shark fin products.

The trade data from these two codes were not included forthis research to avoid being double counted.
While the codes for the five shark fin commodities in Hong Kong were included for analysis withmainland China’s and Taiwan’s data, only the data for raw (with cartilage) shark fins were used to
identify trade trends.

This is to avoid double counting, since the same piece of shark fin can crossa border twice, once when raw and again when processed.

Trends in Hong Kong’s shark fin trade

are particularly revealing as it represents 50% of the global shark fin trade (Clarke 2004).

Tradetrends for shark fin in Hong Kong can therefore be used as an indicator of changes in global
demand.

The volumes of frozen shark fins were factored for water content when comparing thetrade trends in Hong Kong, using a conversion rate of 0.25 (Clarke 2002).

A conversion rate of

0.325 (Anon. 2013a) was used to estimate the production of processed dried shark fins from raw
dried fins.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 4

Taiwan has Customs codes for five different commodities of shark fins, which are chilled, frozen,
dried, salted and smoked shark fins (Annex 2).

Taiwan uses 11 digit Customs codes.

Customs code for “smoked shark fin” was only created in 2013.

The

Taiwan’s Customs codes do notseparate between raw and processed shark fins.

The Customs codes for all five shark fin products

were modified in 2009 and/or 2013 (Annex 2).

The trade records for different Customs codes ofall shark fin products were obtained for this research.
the Bureau of Foreign Trade in Taiwan.

Taiwan’s Customs data were obtained from

Taiwan also has three Customs codes starting with 1604

for preserved/prepared shark fin products.

The trade data from these three codes were notincluded in this research to avoid being double counted.

FAO shark fin trade data between 2005

and 2011 were obtained from FishStatJ to understand the data reporting from mainland China,
Hong Kong and Taiwan.

The most updated FAO shark trade data were available only up to 2011,

before the release of this report.
Searches of seven Chinese-language e-commerce websites were conducted between April andOctober 2015, to document the shark fins and mobulid ray gill plates availability on e-commerce
platforms.

The surveyed websites included the two Chinese language business-to-consumer(B2C), one Chinese consumer-to-consumer (C2C), three Chinese business-to-business (B2B) and
one English language B2B websites (Table 9).
To understand the shark fin and mobulid ray gill plate markets in mainland China, Hong Kong andTaiwan, 150 dried food product retail outlets from seven cities were selected for quantitative market
surveys between May and June 2015 (Table 1).

A range of publications, especially in Chinese, on

the trade in shark fin and mobulid ray gill plates in mainland China, Hong Kong and Taiwan werereviewed to identify key locations for the survey to plot the trade in this region.

Qualitative

surveys, including in-depth interviews with sixteen managers or owners from shark fin trading/wholesaling/retailing companies, were also conducted.

Both quantitative and qualitative surveys

were conducted by professional market surveyors, working with a pre-designed survey
questionnaire (Attachment 1).

For the quantitative market surveys, trained market surveyors

posed as potential buyers to collect information on shark fin and mobulid ray gill plate trade,including product categories, price, species used, origin, etc.

Information on shark species andshark fin were recorded based on the responses of interviewees, but not the judgement of surveyors.
Eight cities were selected for market surveys based on the information related to high-end
consumption, high population density, and the prevalence of a high number of shark businesses:
Beijing, Shanghai, Guangzhou, Shenzhen and Puqi12 in mainland China, Hong Kong as well as
Taipei and Kaohsiung in Taiwan.
12

Only quantitative surveys were conducted in Shenzhen; and only qualitative surveys were conducted in
Puqi.

5 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Table 1. Number of shops visited for quantitative survey and managers interviewed for
qualitative survey
Number of shops

Number of staff

quantitatively

qualitatively

surveyedinterviewed

Beijing15

2

Shanghai

15

2

Puqi

0

2

Guangzhou

30

3Shenzhen

15

0Hong Kong

30

3

Taipei30

2Kaohsiung

15

2

TOTAL

150

16

CitiesNote: The quantitative survey was not taken in Puqi, because only a limited number of shops remains
in operation.

The qualitative interview was not conducted in Shenzhen because of its close locationand comparable business operation patterns as in Guangzhou.
Puqi is a small coastal city in the southeast of Zhejiang Province, which has been processing sharks
since the early 1980s.

Since 2004, however, it has become the main shark processing centre in

mainland China, handling 90% of shark processing in mainland China (Anon. 2014a).

Most of the

sharks processed in Puqi were supplied from Shandong and Fujian in mainland China, as well as fromSoutheast Asia, Europe and America.

According to the China Shark Industry Report (Anon.,2013a), the processing industry in Guangdong focused more on shark fin processing, while Puqi wascapable of processing the whole shark; Puqi is famed for its capacity to process many different partsof a shark, including fin, cartilage, skin, meat, oil and head etc.
The shark processing industry in Puqi has decreased significantly in recent years. There were only
three processing factories left in 2014 (Anon. 2014c); compared with 21 factories processing 7,000 t
per year in 2008 (Anon. 2014a).

A shark processing company from Puqi claimed, on the company’s

introduction, that their products were supplied to Zhejiang, Guangdong, Fujian and Shandong
Provinces in mainland China, as well as Hong Kong, Taiwan, Sri Lanka, Japan and Singapore (Anon.
2015a).
The shark processing industry in Puqi reached peak production in 2009 and 2010, and started to fallin 2011 (Sun 2014).

A journalist from Hong Kong, who visited Puqi in May 2011, released findings

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 6

and images of the shark industry.

This report generated a lot of criticism about the shark industryin Puqi; people there claimed that the reduction in production in Puqi was a direct consequence ofthe report (Sun 2014).
Ida Road in Guangzhou was considered the largest dried seafood wholesale market in Asia (Anon.,2013a).

A trader claimed that the dried seafood trade in Ida Road accounted for 70% of the national

trade volume more than 10 years ago, but had decreased to less than 10% of that volume in recent
years (Anon., 2012b).
The average monthly currency exchange rate in April 201513 between Chinese Yuan, Hong Kong
dollars and Taiwan dollars, compared with the US dollars, as well as the average monthly exchange
rate in June 2012 between Chinese Yuan and US dollars were obtained from online sources14.

13

In April 2015, one Chinese Yuan was equal to USD 0.1636, one Hong Kong Dollar was equal to 0.1290 USD
and one Taiwan Dollar was equal to USD 0.0327. In June 2012, one Chinese Yuan was equal to USD 0.1579.
14
http://www.oanda.com/currency/historical‐rates/

7 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

RESULTS
CITES trade data
A total of two full genera and an additional eight species of sharks and rays are listed in CITES
Appendix I and II (Annex 1).

There was no record in the UNEP-WCMC database, where the

CITES data are hosted, of the trade in any ray species, but the rays and a number of shark listings
did not come into effect until September 2014 so they may not appear in the available data sets.
Four species of shark and one genus of sawfish (Pristis spp) were traded by mainland China, Hong
Kong and Taiwan between 2003 and 2013.

In total, mainland China, Hong Kong and Taiwan

imported shark species from eight countries and (re)exported to four countries.

However, only

Hong Kong reported imports of the fins (6,933.4 kg) – Basking Shark Cetorhinus maximus fins from
Norway – and reported the (re)exportation (9 kg) of fins from this same species to Malaysia.
Mainland China and Taiwan recorded trade in shark meat or live sharks, but not in fins.
Singapore reported that a further 39 unknown units of Basking Shark fins, originating from New
Zealand, were re-exported to Hong Kong in 2007, but Hong Kong did not report their import.
Globally, after Hong Kong, the next largest importer of fins from CITES-listed species was Spain,
which reported only 602 kg of Porbeagle Shark Lamna nasus fins imported from Japan during thesame period.
Based on the import declarations in the UNEP-WCMC managed CITES trade database, mainland
China only reported the importation of 6 kg of Basking Shark derivatives from Australia between
2003 and 2013 (Table 2).

However, the USA (2 pieces of skin), UK (1 carving), Norway (700 kg ofmeat) and Germany (3 teeth of Appendix I Pristis spp.) all declared exports of shark products to
mainland China between 2003 and 2013 (Table 2).

Mexico reported exports of 40 specimens15 of

Whale Shark Rhincodon typus to Taiwan in 2009, but these were not reported as imports by
Taiwan16.

Hong Kong had declared imports of some fins, skin and specimens of Basking Sharkand Great While Shark Carcharodon carcharias from Norway (6,933 kg of Basking Shark fins), UK(1 piece of Basking Shark skin) and South Africa (87 Great White Shark specimens), while Norway
and Singapore reported exports of 2,855 kg and 39 unspecified units of Basking Shark meat and fins,respectively, to Hong Kong.

15

According to CITES annual reports guideline, the term “specimen” is scientific specimens, includes blood,tissue (e.g. kidney, spleen, etc.), histological preparations, preserved museum specimens, etc.
16
Although Taiwan has regulations for compliance with CITES trade requirements, Taiwan is not a Party to
CITES and does not report its CITES species trade.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 8

Table 2. CITES listed shark species imported into mainland China, Hong Kong and Taiwan
ImporteExporter Termrreportedreportequantity

Unitp

OriginTaxon

ExporterAp

ImporterYeardquantity2003

II

Cetorhinus maximus

CN

AU

ID

6

derivatives

kg

2005

II

Cetorhinus maximus

HK

NO

5,538

fins

kg

2005

II

Cetorhinus maximusHKNO

2,855.4

meat

kg

2005

II

Cetorhinus maximus

CN

US

XX

2

skin pieces

2007

II

Cetorhinus maximus

HK

SG

NZ

39

fins

2007

II

Cetorhinus maximus

CN

NO

700

meat

kg

2008

II

Cetorhinus maximus

HK

NO

700

fins

kg

2009

II

Cetorhinus maximus

HK

NO

119.1

200

fins

kg

2009

II

Rhincodon typus

TW

MX

40

specimens

2011

II

Cetorhinus maximus

HK

GB

2011

II

Carcharodon

HK

ZA

XX

1

skins

87

specimens

carcharias
2011

II

Cetorhinus maximus

CN

GB

XX

1

carvings

2011

I

Pristis spp.

CN

DE

XX

1

teeth

2012

II

Cetorhinus maximus

HK

NO

605.6

fins

2012

I

Pristis spp.

CN

DE

2

teeth

576.3
XX

kg

Source: UNEP-WCMC CITES trade data, 2003-2013
Note: The records of export and re-export were not separated.

Even though information on the

countries/territories of “origin” was recorded in the CITES trade data, there is some inconsistency as
the origin of some species was not within their distribution range, for example, Cetorhinus maximus
from Indonesia.
Hong Kong had greater reported imports of CITES shark products than mainland China andTaiwan.

In contrast, records suggest that (re)exports were greater in mainland China, where manysmall quantities of Basking Shark, Great White Shark and Whale Shark specimens to the USA andSouth Korea were declared by these importing countries (although without corresponding
declarations from mainland China), compared with Hong Kong’s only record of (re)export of 9 kg
of Basking Shark fins to Malaysia in 2006 (Table 3).

Taiwan (re)exported some Great White Shark

9 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

products (12,519 unspecified units of bones17 and 1 carving) and six live Whale Shark (6 live
sharks) to the USA.
Table 3. CITES listed shark species (re)exported from mainland China, Hong Kong and Taiwan
ImporteExporterrreportedreported

quantity

Term

Unit

p

OriginTaxon

ExporterAp

ImporterYear

quantity
2003

II

Cetorhinus maximus

US

CN

2004

II

Cetorhinus maximus

US

CN

2004

III

Carcharodon carcharias

US

2005

II

Rhincodon typus

2006

II

2006

1
XX

carvings

1

skin pieces

TW12,519

bones

US

TW

2

live

Cetorhinus maximus

MY

HK

II

Rhincodon typus

US

TW

2007

II

Carcharodon carcharias

US

CN

2007

II

Rhincodon typus

US

TW

2008

II

Carcharodon carcharias

NZ

HK

2009

II

Cetorhinus maximus

US

CN

2009

II

Carcharodon carcharias

US

CN

2009

II

Carcharodon carcharias

US

TW

2010

II

Rhincodon typus

US

CN

2012

II

Rhincodon typus

US

CN

2012

II

Carcharodon carcharias

US

CN

XX

1

bones

2012

II

Carcharodon carcharias

US

CN

XX

1

bones

2013

II

Rhincodon typus

US

CN

1

specimens

2013

II

Carcharodon carcharias

KR

CN

2013

II

Sphyrna lewini

US

HK

XX

9

fins

2

live

5

teeth

2

live

1

bones

20

derivatives

XX

4

teeth

XX

1

carvings

6

derivatives

XX
XX

3

BR

1
6

kg

g

bodiesspecimens
specimens

Source: UNEP-WCMC CITES trade data, 2003-2013
Note: Some species could be naturally occurring in EEZs as well as on the high seas and be landed bycountries with distant water fleets.

17

This probably should be cartilage and not bone as sharks only possess cartilage. However, cartilage is not
yet a recommended term to describe products in CITES annual reports.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 10

Discrepancies in data from importing and (re)exporting countries and territories are not uncommon
in UNEP-WCMC’s CITES trade database.

The database shows that only Hong Kong (of the threestudy areas) had imported and (re)exported shark fins of CITES listed species (Basking Shark), whileboth mainland China and Hong Kong had imported shark meat.
Mainland China only imported Basking Shark and an unspecified sawfish species, but (re)exported
Basking Shark, Great White Shark and Whale Shark products.
The USA reported imports of six specimens of Scalloped Hammerhead Shark Sphyrna lewini from
Hong Kong in 2013, although the listing for three Hammerhead Sharks were only in effect from
September 2014.

It is not clear why the USA reported their CITES-listed shark species trade before

the listing date, however such practice has happened for other species.
Hong Kong reported 90% (6,933.4 kg) of all shark fin imports from CITES-listed species (7,720.7 kg)
between 2003 and 2013.

Basking Shark Cetorhinus maximus was the only CITES-listed species thatHong Kong reported and Norway was the only country with which Hong Kong had reported trade inits shark fins.

Conversely, the shark fins that Norway reported to export to Hong Kong (805.6 kg)

only accounted for 12% of Hong Kong’s import report from Norway (6,933.4 kg).

Hong Kong also(re)exported 9 kg of Basking Shark fins to Malaysia in 2006, which was not reported by Malaysia.

FAO FishStatJ trade data
The most recent FAO FishStatJ18 trade data were available up to 2011.

FAO’s record of shark fin

imports and (re)exports for mainland China, Hong Kong and Taiwan were, on the whole, in accord
with import and (re)export data kept by the Customs of mainland China, Hong Kong and Taiwan,
except in a few cases (Annex 3a and 3b).
FAO and Hong Kong Customs data matched well.

FAO’s records were slightly higher than Hong

Kong Customs data for the (re)export in 2006, with a 0.05% or 3 t difference.

As with Hong Kong,

the FAO and Taiwan Customs data matched well, except imports in 2007, 2010 and 2011.
records were slightly lower than Taiwan Customs data.
were between 2-10 t, less than 0.1% difference.
matched well in general.

FAO’s

The data difference for Taiwan and FAO

The mainland China FAO and Customs data also

Some small gaps for the import in 2010 (FAO record was about 25 thigher) and export in 2011 (FAO record was about 6 t lower). The import record of 2010, FAO’s
data was about 20% (25 t) more than mainland China’s Customs records.

18

FishstatJ Global commodities production and trade, ver. 2014‐03‐06.

11 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

FAO data showed that, in general, global annual imports and (re)exports were high in 2005, thenslowly decreased towards 2011 (Annex 3b).

The share of mainland China’s import to global

import was 22% in 2005, decreased to 15-19% between 2006 and 2008, 6% in 2009, then further
decreased to 1% in 2010 and 2011.

On the other hand, the import shares of Hong Kong andTaiwan to global annual import were increasing gradually (Annex 3b).

The actual import volumeof Hong Kong was stable (between 9,358 t and 10,348 t) from 2005 to 2011, but the global share ofimports was increasing gradually from 67% in 2005 to 81% in 2011.

Taiwan’s global import share

increased from 3% in 2005 to 10% in 2011, with the actual import volume tripling (increasing from
434 t in 2005 to 1,260 t in 2011).

According to FAO data, in total, mainland China, Hong Kong

and Taiwan accounted for 91-93% of global shark fin annual import and 63-77% of global shark fin(re)export each year (Annex 3b).

According to Hong Kong’s re-export data, mainland China andViet Nam have significantly under-reported their annual shark fin imports to FAO.

Such under-

reporting does make it difficult to understand the volume and role that different
countries/territories play in the global shark fin trade, although it does help to avoid the problem of
double counting, given that the same shipment of shark fins can be transited through borders morethan once.

According to the estimation by Dent and Clarke (2015) based on the Customs data ofmajor shark fin trading countries/territories, the estimated global shark fin imports were 11% to
18% higher than FAO recorded between 2005 to 2011, the estimated annual (re)export were 5% to146% higher during the same period.
According to the estimation by Dent and Clarke (2015), the global shark fin import decreasedslightly from 2005 to 2014, but the (re)exports increased slightly and peaked in 2007 (23,408 t)(Annex 4).

Based on Dent and Clarke’s estimation (2015), mainland China, Hong Kong andTaiwan’s global share of shark fin trade was lower, accounting for 78-84% of global annual importand 31-47% of global annual (re)export (Annex 4).

The annual shark fin import share(percentage) of mainland China, Hong Kong and Taiwan to the estimated world import was close
between the FAO and Dent & Clarke (2015) estimation (Annex 3b and 4).

The shark fin(re)export share of mainland China to the rest of world was also similar between the FAO and Dent
& Clarke estimation.

However, the share of shark fin (re)export of Hong Kong and Taiwan to therest of world was significantly lower for the Dent & Clarke estimation between 2007 and 2011
(Annex 3b and 4).

This is because the FAO recorded global annual imports were close to the Dent

& Clarke (2015) estimation, but FAO’s (re)export data were significantly lower than the Dent &Clarke (2015) estimation, especially between 2007 and 2011 (Annex 3b and 4).

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 12

Customs trade data
There are no Custom codes specifically designed for mobulid ray gill plates, or any fish gill plates, inmainland China, Hong Kong and Taiwan.

Thus, no analysis on the mobulid ray gill plate trade,based on Customs data, was possible.
Mainland China’s shark fin imports and (re)exports
Mainland China has only one Customs code to record the shark fin product trade, there are no
separate Customs codes for the different shark fin commodities.

In total, mainland China

imported around 11,727 t and (re)exported 4,143 t of shark fins between 2005 and 2014 (Table 4).
Table 4. The total import and (re)export of shark fins in mainland China (kg), 2005-2014
Shark fins

Import (kg)(Re)export (kg)

11,727,045

4,143,137

Source: Mainland China Customs data, 2005-2014
In general, mainland China’s shark fin imports and (re)exports decreased between 2005 and 2014
(Figure 1).

During these 10 years, mainland China’s shark fin imports decreased dramaticallyfrom more than 3,338 t in 2005 to slightly more than 120 t in 2010.

After a small increase to morethan 159 t in 2011, the shark fin import has further declined to less than 20 t in 2014 (Annex 3).
Compared with the previous year, imports declined by 20% in 2006, another 20% in 2008, andfinally at a much greater scale with more than 60% decrease in 2009 and 80% in 2010.
Mainland China’s shark fin (re)export volumes were around 1,350 t in 2005, falling dramatically toaround 382 t in 2006, and remaining at low levels, between approximately 200 and 400 t, until 2014
(Figure 1 and Annex 3a).

Mainland China’s annual import volumes of shark fins were higher than(re)export volumes between 2005 and 2009, but this trend was reversed from 2010 to 2014.

13 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Figure 1. Mainland China shark fins annual import, (re)export and retention (t), 2005-2014
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
‐500

2005

2006

retention

2007

2008

Import

2009

2010

2011

(Re)export

2012

2013

2014

3 yrs moving average

Source: Mainland China Customs data, 2005-2014
From 2005 to 2014, mainland China imported shark fins from a total of 39 countries/territories.
Taiwan (3,350 t, 29%), Singapore (1,679 t, 14%), the Philippines (1,331 t, 11%), Indonesia (909 t,
8%) and Spain (900 t, 8%) were the top five suppliers, which together accounted for 70% of
mainland China’s shark fin imports.

Hong Kong ranked 8th, accounting for 5% (585 t) ofmainland China’s shark fin imports over the 10-year period.

During the first five years of thisperiod, mainland China sourced its shark fins from a total of 36 (15-27 annually, 21 in average)
countries/territories, but imports originated from only a total of 11 (2-6 annually, 4 in average)
countries/territories between 2010 and 2014 (Figure 2).

Mainland China imported only 1-6% of

shark fins annually from Hong Kong between 2005 and 2010, but this increased to 27-33% between
2011 and 2014.

The most consistent trade partners of shark fins to mainland China, those withwhich it traded for eight or more years, include Hong Kong, Japan and Senegal. The majority ofimports from the top five supplying countries/territories occurred in the first five years.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 14

Figure 2. The percentage of shark fins imported by mainland China, from different supplying
countries/territories
100%
HK

HK

HK

80%

HK

HK

60%

40%
TW

20%
TW
0%

TW

HK
TW

TW

HK

HK

HK

HK

TW
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

TW

SG

PH

ID

ES

CR

PK

HK

YE

SN

AR

BR

JP

VU

CA

BN

VN

GT

IN

FJ

US

EC

AE

UY

MX

BE

LK

ZA

CL

DJ

MM

BD

NZ

OM

MA

PE

SO

VE

MY

Source: Mainland China Customs data, 2005-2014
Over this same period, mainland China (re)exported shark fins to only nine countries/territories(Figure 3).

Around 69% (2,848 t) of shark fins were (re)exported from mainland China to Hong

Kong, 18% (743 t) to Japan, 5% (225 t) to Singapore, 5% (204 t) to Taiwan and 3% (114 t) to Sri
Lanka.

(Re)exports from mainland China to Hong Kong decreased sharply from 1,144 t in 2005 to

256 t in 2006, and further decreased to 148 t in 2010. The (re)export from mainland China toHong Kong had risen slightly in 2011 and 2012, then reduced again to 122 t in 2014.

MainlandChina (re)exported relatively constant amounts of shark fins to Japan between 2005 and 2009.
(Re)export volumes declined during the years 2010 to 2012, but recovered to earlier levels in 2013
and 2014, but not as high as in 2005.
slightly during 2013 and 2014.

The (re)exports from mainland China to Taiwan increased

Incidental and mostly low level (re)exports from mainland China

to Sri Lanka, Macau, Spain, Thailand and Australia occurred between 2005 and 2014.
China (re)exported shark fin to Sri Lanka only in 2011 (114 t).

15 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

MainlandFigure 3. The percentage of shark fins (re)exported by Mainland China to different destination
countries/territories, 2005-2014

100%
TW

SG

PH

ID

ES

HK

40%

JP

LK

20%

MO

TH

80%
60%

AU

0%
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Source: Mainland China Customs data, 2005-2014
Mainland China’s Customs data showed that it had imported large amounts of shark fins fromnumerous countries/territories, only 5% (585 t) in total in ten years were imported from Hong Kong,which seems to refute the common impression that most of the shark fins imported by mainland
China were transited through Hong Kong.

However, Hong Kong’s Customs data reveal thatmainland China may be under-reporting the amount of shark fin imports received from Hong Kong,
with higher export figures reported by Hong Kong (27,267 t, adjusted with frozen meat) than arerecorded by mainland China as its imports from Hong Kong. This discrepancy is likely to haveoccurred because importers in mainland China avoided tariffs by declaring commodities as “forprocessing” (Clarke 2002), a classification which was not included in the mainland China Customs
statistics.
According to mainland China’s Customs data, its shark fin imports not only decreased in volume butwere also sourced from fewer countries/territories over time.

Dent and Clarke (2015) reported thatthe decreasing shark fin trade observed in mainland China could be a result of the decreased demand,
trade reporting practices and increased domestic production, or a combination of the above.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 16

Taiwan’s shark fin imports and (re)exports
Taiwan has Customs codes for five different commodities of shark fin, which are chilled, frozen,
dried, salted and smoked shark fins.
processed shark fin.

However, these Customs codes do not separate the raw vs.

Overall, Taiwan imported around 8,732 t and (re)exported around 7,574 t ofshark fins between 2005 and 2014 (Table 5).

More than 99% of the shark fins that Taiwan

imported and exported were either frozen or dried. Around 85% of the imported shark fins werefrozen and more than 66% of (re)exported shark fins were dried (Table 5).

Taiwan imported

22,182 kg of chilled shark fin, or less than 0.3% of the total, and exported 6,991 kg, or around 0.09%,
over the 10-year period.

Taiwan only imported and (re)exported very small amounts of salted

shark fins from mainland China (6 kg) and to Saudi Arabia (840 kg).

The smoked shark fin code

was created in 2013, and resulted in no trade records over this study period.
Table 5. Taiwan import and export volumes of different types of shark fin (kg)Commodities

ImportExportChilled

22,182 (0.25%)

6,991 (0.09%)

Frozen7,399,020 (84.73%)

2,563,345 (33.84%)

Dried

1,310,826 (15.01%)

5,002,866 (66.05%)

Salted6 (0.00%)

840 (0.01%)

Smoked0 (0%)

0 (0%)

Total

8,732,034

7,574,042

Source: Taiwan Customs data, 2005-2014
Taiwan imported shark fin from a total of 60 countries/territories between 2005 and 2014, tradingwith between 17 and 32 suppliers annually.

The top ten suppliers were Spain (1,627 t, 19%),

mainland China (1,343 t, 15%), Indonesia (922 t, 11%), Costa Rica (733 t, 8%), Trinidad and Tobago(621 t, 7%), Pakistan (614 t,7%), Singapore (440 t, 5%), Suriname (398 t, 4.6%), Gambia (389 t,
4.5%) and El Salvador (286 t, 3.3%), which account for 85% of Taiwan’s total shark fin imports19.
Taiwan only imported 440 t and 60 t of shark fin from Singapore and Hong Kong, respectively, or
5% and 0.7% of Taiwan’s total imports between 2005 and 2014.

While Taiwan imported shark finfrom at least 25 countries/territories each year between 2008 and 2012, the number of supplying
countries/territories dropped significantly in the most recent years, from 29 in 2012 to 17 in 2013
and 2014.
Mainland China (624,248 t in total) was Taiwan’s largest supplier of dried shark fin over the 10-year
period, gradually increasing from 26 t in 2005 to 117 t in 2011, and then dramatically dropping to
19

The top five suppliers accounted for 60% of Taiwan shark fins import.

17 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

53 t in 2012 and 38 t in 2014.

Indonesia (287 t) and India (184 t) ranked as Taiwan’s second andthird dried shark fin suppliers, respectively, over ten years, although trade with India ceased in 2013.
Taiwan’s imports of frozen shark fins were typically less than 200 t from any one country/territory,
except on a few occasions.

The exceptions include more than 200 t of frozen shark fins from Costa

Rica (215 t in 2006), El Salvador (215 t in 2006), Panama (203 t in 2008 and 237 t in 2009), Gambia(333 t in 2010) and Spain (309 t in 2013 and 574 t in 2014).

Taiwan imported between 32 t to 155 t

of frozen shark fins annually from Spain between 2005 and 2012, but these imports increased
significantly to 309 t in 2013 and 573 t in 2014.
Taiwan exported shark fins to a total of 18 countries/territories between 2005 and 2014, but only to
6 to 12 importing countries/territories annually.

The top five destinations – Hong Kong (70%,5,268 t), mainland China (16%, 1,208 t), Singapore (8%, 635 t), Japan (4%, 339 t) and Fiji (1%, 50 t)– accounted for 99% of Taiwan’s raw shark fin exports.
Although Fiji ranks fifth among Taiwan’s shark fin total (re)export recipient countries/territories
between 2005 and 2014, it imported shark fins from Taiwan on relatively few occasions (2007, 2009
and 2011).

Minor trade partners include the UK, Netherlands, USA, Malaysia and Australia,

which imported between 779 and 7,692 kg of shark fins from Taiwan in the same ten-year period.
Taiwan’s annual shark fin imports increased between 2005 and 2011, fell dramatically, by aroundhalf, in 2012 before increasing again in 2013 and 2014 (Figure 4).

The annual (re)export volume

for all shark fin commodities had a slower rate of decline between 2005 and 2008, but increased in2009 and 2010 (Figure 4).

After 2010, the annual (re)exports decreased rapidly until 2013 andonly recovered slightly in 2014.

Taiwan’s annual imports were lower than exports between 2005

and 2008, but reversed from 2009 to 2014 (Figure 4).

The import volumes had increasingly

outpaced export volumes since 2009, reaching a peak in 2013 and 2014.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 18

Figure 4. Taiwan shark fin annual import and (re)export (t), 2005-2014
1,400
1,200
1,000
800
600
400
200
0
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
import(re)export

Source: Taiwan Customs data, 2005-2014
Frozen shark fin accounted for around 85% of the total import volume, and frozen shark fin importtrends matched the pattern of shark fin imports overall (Figure 4 and 5).

Taiwan’s annual importsof dried shark fin fluctuated between 82 to 216 t, which peaked in 2011 followed with a more than
50% drop in 2012, and a continued decrease in 2013 and 2014. Dried shark fin (66%) was the maincommodity reported among Taiwan’s shark fin exports, while frozen shark fin accounted for onethird of export volumes between 2005 and 2014.

The export volume of frozen shark fin peaked in2010 and 2011, but fell dramatically in 2012 and remained at low levels in 2013 and 2014 (Figure 5).
Figure 5. Taiwan annual shark fin import & export for dried & frozen shark fin (t), 2005-2014
1,200
1,000

export dried
shark fin

800

export frozen
shark fin

600

import dried
shark fin

400
200

import frozen
shark fin02005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Note: The chilled (<0.3% for ten years) as well as salted (<0.01% for ten years) shark fin were traded insmall amounts and not in every year.

19 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

With the exception of 2005, Taiwan imported more frozen shark fins than it exported over the tenyear period.

The gap between Taiwan’s annual import and export of frozen shark fins has

increased gradually over the ten-year period.
Of the top ten suppliers of Taiwan’s shark fin imports, four were in Asia (38%), four in the Americas(23%), one in Europe (19%) and one in Africa (5%).

In contrast, 98% of Taiwan’s total shark finexports were to just four importers in Asia (mainland China, Hong Kong, Singapore and Japan), 86%of these to Hong Kong and mainland China.
The decreasing export of frozen shark fin from Taiwan may be the result of lower demand in Taiwan’s
key export markets, such as Hong Kong and mainland China.

The decreasing import by the main

global shark fin importers could explain why Taiwan has gradually imported and retained morefrozen shark fin.

It is not clear to what extent shark fin consumption in Taiwan plays a role in theincreases in imports and decreases in exports in recent years.

A report in 2012 claimed that theowners of fishing vessels piled up shark fins in their freezers, but are not selling them because of the
reducing market demand and decreasing price (Lu, 2012).

This suggests that a growing shark finmarket in Taiwan is unlikely to be the driver of the observed changes in Taiwan’s imports and exports.
Taiwan’s shark fin exports to mainland China have fluctuated but, overall, show a decreasing trend
including a 70% decrease in exports to mainland China between 2009 and 2010.
Comparing the trade volumes recorded by Taiwan and mainland China, regardless of the direction of
trade, importers reported higher volumes than exporters did (Annex 5).

For the trade from Taiwan

to mainland China, mainland China’s reported import volume was 2.77 times Taiwan’s reported
exports volume.

For the trade from mainland China to Taiwan, Taiwan’s import volume records

were 6.6 times China’s reported export volume.

The data also showed that in earlier years, especiallyfrom 2005 to 2007, the shark fin trade between mainland China and Taiwan was dominated by exports
from Taiwan to mainland China, but this changed in 2010 when China began exporting more than it
was importing to Taiwan (Figure 6).
It is not clear if higher import declarations were due to stricter import inspections on both sides forthe bilateral trade.

It is equally not clear if there was any connection between the under-reportingof shark fin export volumes by mainland China and Taiwan and IUU shark fisheries.

Obviously,

traders would be motivated to under-report their export volumes if shark fin without appropriate
catch documents were in the trade mix.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 20

Figure 6. The import and (re)export reported for the trade between mainland China andTaiwan (t), 2005-2014
6a. trade from Taiwan to mainland China

6b. trade from mainland China to Taiwan

1,500

400

1,000

300
200

500
100
‐

‐
CN reported import from TW
TW reported export to CN

CN reported export to TW
TW reported import from CN

Source: Mainland China and Taiwan Customs data, 2005-2014
Hong Kong’s shark fin imports and (re)exports
In order to compare data with mainland China as well as with Taiwan, Hong Kong’s five shark fin
commodities (raw and processed) were included in the shark fin trade analysis.
fin data were adjusted

20

The frozen sharkby including the frozen meat component. The water content in frozen finscompared with dried fins was not factored into the analysis.
Hong Kong was handling around 50% of the world’s total shark fin exports (Clarke 2004).

However,more recent data indicate that Hong Kong probably only accounted for 20-40% of the global shark finexport between 2007 and 2011 due to the significantly increased export share of Thailand21 (Dent &Clarke 2015).

Hong Kong however remains the largest global shark fin importer (Dent & Clarke 2015).

Therefore, Hong Kong’s trade patterns can be, and are still, somewhat representative of changes in
global trade.

In order to avoid double counting, only the raw (with cartilage) shark fin data wereanalysed to assess for trade trends over time.

The volumes of frozen shark fin imported and(re)exported by Hong Kong were adjusted, factoring in its water content, before it was used to reveal
Hong Kong’s trade trends over time.

A conversion rate of 0.25 for water content was used (Clarke 2002).

Hong Kong’s shark fin imports and (re)exports were around 88,738 t and 43,829 t, respectively, between
2005 and 2014 (Table 6 and Figure 7).

These figures have been adjusted to include frozen shark meat,but do not factor in its water content.

The main commodity in Hong Kong’s shark fin trade was raw(with cartilage) shark fins, accounting for 97% of total import and 91% of total (re)export volumes (Table
6).

More than half (54%) of the raw shark fin that Hong Kong imported and (re)exported was infrozen form.

Most of the processed fin (without cartilage) that Hong Kong imported (92%) and(re)exported (74%) was in dried form.

20
21

Trade volumes of frozen shark meat between 2012 and 2014 were included as frozen raw shark fin.
Thailand probably accounted for 34‐56% of global export between 2007 and 2011. (Dent & Clarke 2015)

21 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Table 6. Hong Kong adjusted (but not factored) all shark fins import and (re)export (kg), 20052014
Shark fin types

Import(Re)export

dried shark fin with cartilage

39,631,495 (44.66%)

18,652,410 (42.44%)

frozen shark fin with cartilage

35,487,519 (39.99%)

18,143,430 (41.28%)

frozen shark meat*

10,700,081 (12.06%)

3,205,015 (7.56%)

4,503 (0.01%)

26,194 (0.06%)

Subtotal of raw shark fin

85,823,598 (96.71%)

40,027,049 (91.35%)

dried shark fin without cartilage

2,675,823 (3.02%)

2,796,417 (6.36%)

frozen shark fin without cartilage

238,913 (0.27%)

1,006,461 (2.29%)

Subtotal of processed shark fin

2,914,736 (3.29%)

3,802,878 (8.65%)

Adjusted Total

88,738,334

43,829,927

shark fin

Source: Hong Kong CSD, 2005-2014
Note: Hong Kong changed some of its shark products Customs coding system in 2012 and re-classified
wet shark fins as frozen shark meat. The data for frozen shark meat, between 2012 and 2014, were
adjusted to show trade trends more accurately in the frozen shark fin trade.
Figure 7. Hong Kong total shark fin annual import, (re)export and retention (t), 2005-2014
12,00010,000
8,000
6,000
4,000
2,000
‐
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
retention

import(re)export

Source: Hong Kong Customs data, 2005-2014
Note: Hong Kong changed some of its shark products Customs coding system in 2012 and re-classified
wet shark fins as frozen shark meat. The data for frozen shark meat, between 2012 and 2014, were
adjusted to show trade trends more accurately in the frozen shark fin trade.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 22

Raw & Processed Fins
Based on the frozen meat and fin category of the Customs data (adjusted but not factored for watercontent), Hong Kong imported raw and processed shark fins from 115 countries/territories between
2005 and 2014.

Spain (27%, 24,082 t), Singapore (12%, 10,530 t), Taiwan (10%, 8,458 t), Indonesia(6%, 5,690 t), United Arab Emirates (5%, 4,167 t), Costa Rica (3%, 2,572 t), Yemen (3%, 2,400 t),
Mexico (2%, 2,162 t), the US (2%, 2,032 t) and Japan (2%, 1,791 t) were the top ten suppliers forHong Kong’s shark fin imports, accounting for 72% of Hong Kong’s total import volumes (the top
five accounted for 60% of the total import volume).

Imports from Hong Kong’s top ten supplying

countries were more likely to be raw than processed shark fins.

Only 708 t (0.8%) of shark fin wasreported to have been imported from mainland China, making mainland China the 22nd largest
shark fin supplier to Hong Kong.

More than 71% of the shark fin that Hong Kong imported frommainland China was processed shark fin.
Based on the adjusted but not factored Customs data, Hong Kong (re)exported shark fins to 31
countries/territories between 2005 and 2014.

Mainland China was the largest recipient,accounting for 62% (27,147 t) of Hong Kong’s total (re)export volumes, followed by Viet Nam (21%,9,227 t), Japan (4%, 1,841 t), Taiwan (4%, 1,746 t) and Singapore (3%, 1,343 t), which together
accounts for 94% of Hong Kong’s total (re)exports22.

Most shark fin that Hong Kong (re)exported

to Viet Nam (99.7%), mainland China (94%), Japan (77%), Taiwan (77%), Singapore (76%) and
Thailand (91%) was raw, as opposed to processed, shark fin.

However, it is not clear if some or allof these imported raw shark fins were processed in these importing countries/territories.

For

example, research has found that Singapore does not process fins for export (Boon, 2016).
Trade reporting gaps between Hong Kong and mainland China, Taiwan
In contrast to the reporting pattern observed between mainland China and Taiwan, exporters in the
shark fin trade between mainland China and Hong Kong reported higher volumes of trade thanimporters.

For trade between Hong Kong and mainland China, Hong Kong consistently reported

higher export volumes than mainland China reported as imports throughout the ten-year period,
from 2005 to 2014 (Figure 8a). In the reverse direction, mainland China declared higher export
volumes than Hong Kong declared as imports, in nine out of ten years, with the exception of 2010
(Figure 8b).

22

Top ten importers accounted for 99% of Hong Kong’s (re)export. Macau, Thailand, South Korea, the USA
and Canada ranked 6th to 10th.

23 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

According to Clarke (2002), importers in mainland China avoided tariffs by declaring commodities
as “for processing”.

This particular classification was not included in the mainland China Customs

statistics, thus resulting in a large discrepancy between Hong Kong’s exports to mainland China andmainland China’s imports from Hong Kong.

Such practices apparently still exist. These tradereporting discrepancies were, however, decreasing due to the reduction in re-exports from Hong
Kong.

With Hong Kong’s free port status, it is not clear why Hong Kong recorded fewer imports

compared with mainland China’s (re)export volumes in the trade from mainland China to Hong
Kong.
Clarke (2002) found that the trade data discrepancies were less significant for the southbound trade(from mainland China to Hong Kong).

This is also evident in the trade records between 2005 and2014.
Figure 8. The import and (re)export reported for the trade between Hong Kong and mainland
China (t), 2005-2014
8a. from Hong Kong to mainland China
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0

8b. from mainland China to Hong Kong
1,500
1,000
500
‐

CN reported import from HK
HK reported export to CN

CN reported exported to HK
HK reported import from CN

Source: Hong Kong and mainland China Customs data, 2005-2014
In total, Hong Kong reported the re-export of 27,127 t (adjusted with frozen meat) of shark fin to
mainland China from 2005 to 2014, in volumes between 83 t and 6,273 t annually.

After replacing

mainland China shark fin import from Hong Kong with Hong Kong’s re-export data, mainland
China’s shark fin total imports increased from 11,727 t to 38,270 t between 2005 and 2014 (Figure 9
and Annex 7).

Adjusting for the volume Hong Kong (re)exported to mainland China, mainland

China’s shark fin imports still showed a large decrease from 2005 to 2010, which then remained
stable for two years until 2012, followed by another decrease in 2013 and 2014.

The shark fin

retention in mainland China (import minus export), largely increased between 2005 and 2009; thenegative retention between 2010 to 2012 became positive after adjusting the original annual importwith Hong Kong’s (re)export to mainland China (Figure 9).
2013 and 2014 was still negative.

However, the adjusted retention in

Mainland China’s own fishing (inshore and high seas) and stocks

from earlier years are possible sources of shark fin to fill the gap for this negative retention.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 24

Figure 9. Mainland China shark fin import and retention (t), original as well as adjusted with
Hong Kong’s re-export to mainland China, 2005-2014
9,000
7,000
5,000
3,000
1,000
‐1,000

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

original importimport, adjust HK to CN

original retention

retention, adjust HK to CN

Source: Customs data for mainland China and Hong Kong, 2005-2014
Data included the raw and processed fin commodities, but were not factored with water content
Since 2008, residents in the designated border zone in mainland China have been subject to a zero
import tariff if the import value is equal or less than CNY8,000 per person per day (Anon. 2008). Thiswas part of a general policy to boost trade, applied all along the Chinese border.
In November 2012, Customs in Jiangmen investigating a 2010 seafood smuggling case uncovered anillegal trade in shark fin from Viet Nam through Guangxi to Guangdong (Anon. 2013b and 2014d).
Ten suspects from two companies, one trading and one processing, were apprehended; 357 t of frozen
shark fins (212 t, 59% of total seized products), sea cucumber (3.3 t), fish bone (27 t) and others,
worth CNY1.19 trillion in total, were confiscated in late 2012.

The trading company, withinvestment derived from Hong Kong23, worked with several shark fin traders to under-report theimport value of shark fins for over ten years (Anon. 2014d).

Further investigation of this case foundthat this trading company was involved in the smuggling of more than 11,531 t of shark fins, sea
cucumbers and other seafood, worth CNY1.13 trillion, between May 2005 and December 2012
(Anon. 2014d).

The processor was involved in smuggling 676 t of shark fin and other seafood, worth

CNY 62.5 million, between March 2009 and November 2012 (Anon. 2014d).

This processor had

under-reported by as much as 87.5% of the import value of approximately 72 t of shark fin (Anon.
2014d).

The trading company was fined CNY200 million for violation of tariff regulations, andeight out of the ten suspects were sentenced to imprisonment for three to twelve years (Chen et al.
2014).

23

It is not clear if this company was owned and/or 100% invested from Hong Kong. Many shark fin
processors in Hong Kong have moved their factories to Jiangmen, Guangdong since 1986 after the regulation
relating to “offensive trades” was applied to shark fin processing in Hong Kong.

25 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

According to Customs data, mainland China imported 11,668 t of shark fins between 2005 and 2012,
567 t of those were from Hong Kong.

Mainland China did not report shark fin imports from Viet

Nam during the study period, 2005-2014, other than 32 t in 2012.

Hong Kong reported (re)exportsof 26,931 t and 6,436 t of shark fins (raw, processed and adjusted with frozen meat) to mainland China
and Viet Nam, respectively, between 2005 and 2012.
If Viet Nam’s shark fin import is adjusted using Hong Kong’s (re)export data, Viet Nam potentially
imported at least 6,436 t of shark fin between 2005 and 2012.

Even though the shark fin case in

Jiangmen demonstrated that large amounts of shark fins were smuggled into mainland China via Viet
Nam between 2005 and 2012, only 212 t of shark fins were actually seized. This would account for
approximately 3% of the shark fin (re)exported from Hong Kong to Viet Nam over the same period.
The remaining amount (re)exported to Vietnam could potentially have been consumed domesticallyor (re)exported to other countries (including potentially mainland China), or purchased by foreign
tourists as souvenirs.

Although mainland China was considered to be the largest shark fin market(Dent & Clarke, 2015), there is not sufficient information to estimate how much shark fin is entering
mainland China from Viet Nam.
Trade reporting between Hong Kong and Taiwan
Regardless of the direction of trade between Hong Kong and Taiwan, Hong Kong’s reported tradevolumes were higher than Taiwan’s declared volumes in 19 out of 20 cases, from 2005 to 2014
(Figure 10a and 10b).
The Hong Kong-Taiwan reporting discrepancies were greater when Taiwan was the importer thanwhen Taiwan was the exporter.

In 2005, the only exception, Taiwan reported higher export volumes

than Hong Kong’s declared imports. Clarke (2002) observed the same pattern through trade trend
research and suspected that the import tariff in Taiwan may be encouraging under-reporting of its
imports (Clarke 2002).
Although the trade from Hong Kong to Taiwan gradually increased, peaking in 2011, it wasconsistently less than the trade from Taiwan to Hong Kong during the ten-year period.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 26

Figure 10. Reported import and (re)export trade between Hong Kong and Taiwan (t), 2005-201410a. from Taiwan to Hong Kong
1,400
1,200
1,000
800
600
400
200
‐

10b. from Hong Kong to Taiwan
350
300
250
200
150
100
50
‐

TW reported export to HK
HK reported import from TW

TW reported import from HK
HK reported export to TW

Source: Hong Kong and Taiwan Customs data, 2005-2014

Processed Fins
On average, only 3% of shark fins Hong Kong imported were processed fins. The proportion was
higher in 2005 (more than 10%), and fell to 0.2% to 5% annually between 2006 and 2014. Spain (26%,749 t), mainland China (17%, 504 t), Singapore (11%, 315 t), Taiwan (7%, 192 t) and the Philippines(6%, 185 t) were the top five suppliers for Hong Kong’s processed shark fin imports. However, it is
not clear if some or all of the fins were processed in these supplier countries/territories or elsewhere.
For example, research has found that Singapore does not process fins for export (Boon, 2016).
Mainland China and the Philippines were the only two suppliers that were not top ranking suppliersin Hong Kong’s overall shark fin imports, but were significant players in the supply of processed fin
to Hong Kong. Around 71% of shark fin that Hong Kong imported from mainland China wasprocessed fin. About 92% of the imported processed shark (not factored) fins from mainland China
to Hong Kong were in dried form, with the remaining 8% in frozen form. Around 9% (3% to 16%
annually) of the shark fins that Hong Kong (re)exported were processed fins; 74% of these processed(re)exported shark fins (not factored) were in dried form. Mainland China (43%, 1,615 t), Japan (11%,424t), Taiwan(11%, 406t), South Korea (9%, 345t), Singapore (8%, 321t), the USA(7%, 258t),
Canada(5%, 173t), Macau (3%, 121t), Thailand (1%, 46t) and Malaysia(1%, 33t) were the top ten
importers of Hong Kong’s processed shark fin. South Korea (87%), USA (75%) and Canada (74%)
were the only three of these importing countries which imported more processed fins than raw finsfrom Hong Kong.
Raw Fins
Hong Kong’s import and (re)export of raw shark fins (adjusted and factored) were around 51,183 t
and 24,016 t, respectively, between 2005 and 2014 (Table 7).

Of this, 77% of total import and 78%

of total (re)export volumes were in a dried form (Table 7).

Around half of raw shark fins thatHong Kong imported, including dried and frozen forms, were subsequently re-exported to othercountries/territories.

27 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Table 7. Hong Kong adjusted and factored raw shark fin import and (re)export (kg), 2005-2014
Raw shark fins

Import(Re)export

dried shark fin with cartilage

39,631,495 (77.43%)

18,652,410 (77.67%)

frozen shark fin with cartilage

35,487,519

18,143,430

frozen shark meat*

10,700,081

3,205,015

11,546,900 (22.56%)

5,337,111 (22.22%)

4,503 (0.01%)

26,194 (0.11%)

subtotal of adjusted & factored
frozen shark fin
shark fin, NESOI
Adjusted & factored Total

51,182,898

24,015,715

Source: Hong Kong CSD, 2005-2014
Note: Hong Kong changed some of its shark products Customs coding system in 2012 and re-classified
wet shark fins as frozen shark meat. The data for frozen shark meat, between 2012 and 2014, wereused to adjust frozen shark fin trade.
NESOI: Not Elsewhere Specified or Included
When the water content in raw, frozen shark fins was factored in, Hong Kong’s top suppliers of raw
shark fin imports shifted slightly.

Spain (15%, 7,449 t) remains the largest raw shark fin supplier toHong Kong, followed by Taiwan (10%, 5,002 t), Singapore (8%, 4,061 t), the United Arab Emirates(8%, 3,985 t), Indonesia (7%, 3,681 t), Yemen (5%, 2,394 t), Mexico (4%, 2126 t), Peru (3%, 1607 t),
Japan (3%, 1400 t) and Brazil (3%, 1399 t), which together account for 65% of Hong Kong’s raw
shark fin imports between 2005 and 2014.
When the data were adjusted and factored, both USA and Costa Rica dropped out of the list of the
top ten suppliers of Hong Kong’s raw shark fin imports, and were replaced by Peru and Brazil.
USA (67%) and Costa Rica (73%) supplied a high percentage (before factoring for water content) of
raw fin in frozen form to Hong Kong, but 99-100% of raw shark fin exported from Brazil and Peru
was in dried form.
On average, and before factoring for water content, frozen raw fin accounted for 54% of all raw fin
imported by Hong Kong between 2005 and 2014.

Spain (91%) and Singapore (80%) exported ahigh percentage of frozen raw fin to Hong Kong, while Taiwan (53%) and Indonesia (46%) exported
a moderate percentage of frozen raw shark fin.
With water content factored in, the top five importers of raw shark fin (re)exports from Hong Kong
also changed slightly.

Mainland China (57%, 13,781 t) was still the largest market for Hong Kong’s

raw shark fin (re)exports, followed by Viet Nam (28%, 6,754 t), Japan (5%, 1,308 t), Taiwan (2%, 546

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 28t), and Macau (2%, 461 t), together accounting for 95% of Hong Kong’s total raw shark fin(re)exports between 2005 and 2014.
Before factoring in the water content, 61% and 79% of raw shark fin that Hong Kong re-exported tomainland China and Taiwan, respectively, were in frozen form.

The higher percentage of raw

shark fin that Hong Kong re-exported to Viet Nam (65%) and Japan (90%) were in dried form.

Onaverage, before factoring in water content, frozen raw fin accounted for 53% of all raw fin reexported from Hong Kong between 2005 and 2014.
Comparing the import and (re)export data for factored and non-factored raw shark fin shows that,though largely similar, there are some notable differences (Figure 11).

The non-factored andfactored data showed stable raw shark fin imports from 2005 to 2011, decreasing in 2012 and 2013,
and recovering a little in 2014.

(Re)exports for the non-factored data revealed a mild decrease

from 2005 to 2010, with a more significant decrease from 2011 to 2014.

However, the factored

data showed that (re)exports decreased significantly from 2005 to 2008 and from 2010 to 2012,
while keeping stable in 2009, 2013 and 2014.
Figure 11. Hong Kong annual raw shark fin import and (re)export (t), 2005-2014

11b. factored raw shark fin trade

11a. non‐factored raw shark fin trade
8,000

15,000

6,000

10,000import(re)export

import(re)export

Source: Hong Kong CSD, 2005-2014
Shark fins retained in Hong Kong
Comparing the import and re-export volumes for adjusted and factored raw shark fin shows thatHong Kong was increasingly retaining more shark fin over the period from 2005 to 2011 (Figure
12).

The retained shark fins could be, but are not exclusively, consumed domestically.

In

addition to possible illegal trade, some shark fins could be brought across Customs control border
legally, without declaration, by tourists.

However, this trend changed in subsequent years, withretention decreasingly significantly, by 26% in 2012 and 40% in 2013 (Table 8).

These figures areequivalent to 1,495 t of dried raw fins retained in Hong Kong in 2005, with volumes increasing to

29 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

2014

2013

2012

2011

2010

2009

2008

2007

2006

2014

2013

2012

2011

2010

2009

2008

‐
2007

‐
2006

2,000
2005

5,000

2005

4,000

4,441 t in 2011, and subsequently falling to 3,308 t in 2012, and kept at a low of around 2,000 t in2013 and 2014.
A conversion rate of 0.325 was used to estimate the production volume of processed dried shark finfrom raw dried fin (Anon., 2013a).

After applying the conversion rate, some 8,820 t of processed

dried shark fin could have been produced in Hong Kong from its raw form between 2005 and 2014.
The amount of raw shark fin retained in Hong Kong was equivalent to around 486 t of processed
dried shark fin in 2005, which peaked in 2011 at around 1,443 t, then declined by 26% to 1,075 t in2012, and another 40% fall to 646 t in 2013.
According to the conversion rates given by the China Shark Industry report (Anon., 2013), 8,820 t
of dried processed shark fin, after being soaked in water, is equivalent to 22,049 t of food ingredientshark fins, which is ready for cooking.
Figure 12. Annual changes of Hong Kong raw shark fins import, re-export and retention (t),2005-2014
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0
2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

retained in Hong Kong

adjusted/factored importadjusted/factored exported

retained in HK, conversed as processed fins

Note: Raw shark fins data were adjusted and factored
A China Shark Industry report (Anon., 2013a) indicated that raw fresh/frozen shark fins must go
through two stages before being sold as processed dried shark fin.
dehydration procedure, where the shark fin loses 60-70% in weight.

The first step includes a
The second processing stage

includes removing the skin, cartilage and meat, which turns the raw dried shark fin into processed
dried shark fins.

It will lose a further 65-70% of weight during this second stage process.

Processed dried shark fins are the most typical form that is sold at dried seafood wholesale andretail shops in Hong Kong, mainland China, Taiwan and many other Asian countries.

Thus, 1 kg

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 30

of raw fresh/frozen shark fins equates to 0.09 – 0.14 kg of processed dried shark fins.

The 60-70%

of weight loss given by the China Shark Industry Report (2013) is close to estimations of 70-79%
given by Hong Kong traders (Clarke 2002).

Factors of 0.2524 and 0.325 were used to normalise

shark fin weights in the first and second stages of shark fin processing, respectively.
The China Shark Industry report also claimed that 1 kg of processed dried shark fins, after soaking
in water, yields 2.5 kg of “food ingredient” shark fins, enough for a serving for 10 people (an averageof 250 g of shark fin ingredient per individual).

This figure for an individual serving seems very

high, as research has found that the average shark fin wet weight in a bowl of shark fin soup in Hong
Kong is less than 50 g (WWF-Hong Kong unpublished data) (WWF-Hong Kong unpublished data).
According to the China Shark Industry Report (Anon., 2013a), a survey in June 2012 showed thatsharks harvested from the near shore were landed with fins and internal organs intact, while sharkscaught on the high seas were landed without internal organs.

The auction price for landed sharkswith fins attached was around CNY 20,000 per t (USD 3,158/t), and around CNY 13,000 - 15,000
per t (USD 2,053 - 2,369/t) for sharks without fins.

While a shark’s fins only make up

approximately 5% of its weight, these fins accounted for an incongruously large proportion (2535%) of the value of each shark, by weight.
The report also stated that the monetary value of shark fins depends on the size, quality and the finposition from the sharks.

The most valuable shark fins come from the lower parts of a shark’s

caudal fin, which could yield prices around CNY 2,000 per kg (USD 316/kg). A pelvic and dorsal
fin of standard quality can cost around CNY 300 – 1,000 per kg (USD 47-158/kg); however ones oflower quality can cost less than CNY 100 per kg (USD 16/kg).
The report also found that in mainland China, 75% of shark fins were used by restaurants andhotels, 15% by small wholesalers and 10% were purchased by individuals.

Those shark fins which

went to small wholesalers were eventually sold to restaurants and hotels.

Only a certain group of

the population who came from the coastal area of Guangdong were familiar with shark fin cuisine
preparation, and hence would buy shark fins to cook at home.

24

A lower conversion rate for first stage process was used to keep consistent with several published reports
and to avoid over‐estimation of the possible available amount for consumption.

31 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Table 8. Hong Kong raw shark fins import, (re)export and estimated retention (kg), 2005-2014
2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

Total

Adjusted/fact

5,88

5,33

5,79

5,53

5,55

5,75

6,17

4,39

3,32

3,40

51,18

ored import

7,06

6,70

8,48

5,51

8,38

9,19

4,59

7,99

5,10

9,84

2,922

1

5

6

7

9

6

7

8

4

5

Adjusted/fact

4,39

3,31

2,89

2,54

2,82

2,53

1,73

1,09

1,33

1,34

24,04

ored exported

2,17

3,11

5,65

9,53

1,72

3,65

3,74

0,18

7,58

8,34

5,525

2

7

5

7

6

6

3

9

0

1

Retained in

1,49

2,02

2,90

2,98

2,73

3,22

4,44

3,30

1,98

2,06

27,13

Hong Kong

4,88

3,58

2,83

5,98

6,66

5,54

0,85

7,80

7,52

1,50

7,397

9

8

1

0

4

1

3

9

4

5

Conversed as

485,

657,

943,

970,

889,

1,04

1,44

1,07

8,819,

666

420

443

416

5,03

669,

839

3,27

645,

processed fins

8,30
1

7

8

945

989

654

1,21

1,64

2,35

2,42

2,22

2,62

3,60

2,68

1,61

1,67

4,59

4,16

8,55

6,10

3,53

0,75

8,19

7,59

4,86

4,97

7

5

0

8

9

2

3

5

3

2

Soaked in
water

22,04
9,135

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 32

Online survey
Searches of seven e-commerce websites based in mainland China were conducted between April
and October 2015, in order to document the availability of shark fins and mobulid ray gill plates inthe e-commerce market.

The surveyed websites included three Chinese language business-to-business (B2B), two Chinese language business-to-consumer (B2C), one Chinese language
consumer-to-consumer (C2C), and one English language B2B websites (Table 9).
Table 9. E-commerce websites in mainland China monitored for shark fins and mobulid ray gillplates advertisements
Websites

Language

Target markets

No. of adverts of No. of adverts ofshark finsmobulid ray gillplates#1

Chinese

B2B, Domestic market and7 adverts

Chinese speakers around the

5 shops

0

world
#2

Chinese

B2B, Domestic market and

14 adverts

Chinese speakers around the

11 shops

0

world
#3

Chinese

B2B, Domestic market and

50 adverts

Chinese speakers around the

39 shops/sellers

0

world
#4

EnglishB2B, global market

0

0

#5

Chinese

B2C, Domestic market and9 adverts

8 adverts

Chinese speakers around the

6 shops

6 shops00

0

124 adverts

world
#6

Chinese

B2C, Domestic market andChinese speakers around the
world

#7

Chinese

C2C, Domestic market andChinese speakers around the

90 sellers

world
In total, 212 different advertisements for shark fins and mobulid ray gill plates were found,
representing 156 e-commerce shops/sellers on four websites.

The online survey did not detect asingle shop/seller offering both shark fins and mobulid ray gill plates, and only one shark fin shop,

33 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

located in Guangzhou, had cross-posting advertisements on more than one e-commerce website.
Ninety sellers (57%) were found on the surveyed C2C website, 55 shops (35%) were found on thethree B2B websites surveyed, and 12 shops (8%)25 were found on the B2C website.

There were atotal of 60 e-commerce shops (39%) offering shark fins for sale, while 96 shops/sellers (61%) soldmobulid ray gill plates.

Ninety (95%) mobulid ray gill plate sellers were found on a C2C e-commerce website, while six shops were found on a B2C website.

Many advertisements did notprovide images of the shark fin or mobulid ray gill plate products.

A few advertisements had

images of the fin’s skeletal structure, although this may represent low grade shark fins or fins ofbony fish.

Only eleven shops specified the species name and/or country of origin.

Of the 156 e-commerce shops/sellers, 144 were located in 41 cities in mainland China, five were in
Hong Kong, and seven shops did not specify their location (Figure 13).

One-hundred and forty

shops were located in the coastal provinces from northeast to southeast China, with the other fourshops located in inner provinces: Shenyang of Liaoning, Datong of Shanxi, Wuhan of Hubei andChengdu of Sichuan.

Eighty-eight percent (126/144) of the e-commerce shops of known location

were in provinces around or south of Shanghai.
Figure 13. E-commerce shops found in 42 cities in mainland China and Hong Kong provided
shark fins and mobulid ray gill plates for sale.

Source: Map data ©2015 Google
Guangdong was the province with the largest number of online shops offering shark fins andmobulid ray gill plates (95 shops), equivalent to 66% of the shops in mainland China with known

25

Half (6) of B2C shops sold shark fins, the rest sold manta ray gill plates

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 34

locations, followed by Shandong (8%, 11 shops), Fujian (6%, 8 shops) and Guangxi (6%, 8 shops).
Only four and three e-commerce shops were located in the two largest cities, Beijing and Shanghai,
respectively.

Shark fin B2C e-commerce shops were only found to be located in 6 cities: Dairen,

Tianjin, Jiaxing, Changle, Quanzhou and Guangzhou.
Eleven shops (7%) that sell shark fins had made specific claims about the species or country oforigin of its products. Two shops located in Fujian and Guangxi claimed their shark fins were locallysourced, from Fujian and Beihai, respectively (Table 10).
fins came from the Pacific Ocean.

Another shop in Fujian claimed its shark

Three shops located in Guangdong claimed their shark finsoriginated from Sri Lanka, South Africa, Thailand and Indonesia.
its fins came from Thailand.

One shop in Hubei also claimed

A shop in Sichuan claimed that its fins were sourced from Europe.

One shop located in Zhejiang claimed its fins were Blue Sharks, with images of the fin’s skeletal
structure.

One of the shops in an unknown location had claimed that its shark fins came from

Canada, while another claimed its fins were Oceanic Whitetip Shark Carcharhinus longimanus andElephant Shark from Cameroon.
An advertisement for fins from Elephant Sharks that were caught in Cameroon was found on a
Chinese language B2B website (with a product description in English).
was described in the text of the advert.

The “Elephant Shark fins”

It is not clear what species “Elephant Shark” would be;

while Basking Sharks Cetorhinus maximus are known as elephant sharks in the Chinese language,
the Basking Shark is not found in Cameroonian waters according to the IUCN Red List’s range
map26.
There were 90 sellers from the surveyed C2C website and six shops from a B2C website which
offered dried mobulid ray gill plates for sale.

One online shop claimed its dried mobulid ray gillplates came from Sri Lanka; another claimed its dried mobulid ray gill plates were Spinetail Devil
Ray Mobula japonica, Giant Mobulid Ray Mobulid birostris and Pigmy Devil Ray Mobula diabolis.
Two shops located in Guangzhou and Hong Kong claimed their dried mobulid ray gill plates camefrom Indonesia and the Philippines, respectively.
claimed they provided “shopping service”

27

Three out of five sellers, located in Hong Kong,and their mobulid ray gill plates were purchased from afamous dried food products company in Hong Kong.

Such “shopping service” advertisements

were likely targeting consumers in mainland China.

26

http://maps.iucnredlist.org/map.html?id=4292.
People who purchase the sought‐after products in a location with a lower price and/or sufficient supply,
and resell those purchases for profit.

27

35 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

The observation of the e-commerce websites suggested that the market for mobulid ray gill plates
was more concentrated in southern China, from Guangxi and Guangdong up to Fujian andZhejiang Provinces.

In general, e-commerce shops tend to serve consumers near their location tokeep the package delivering time and cost at a manageable level.

Most of the shops/sellers (83, or

86%) of shops selling mobulid ray gill plates were located in Guangdong, while two other sellers inGuangxi offered shipments from Guangdong, and three sellers in Hong Kong offered a “shopping
service” to target consumers in southern China.

The “shopping service” is used commonly bymany Chinese consumers, especially for purchasing commodities from abroad.

There was only

one e-commerce seller found in Zhejiang, located near the shark processing centre (Puqi).
It appears as though most mobulid ray gill plates were stored in Guangdong, since many of the ecommerce sellers were in Guangdong and offered delivery from there.

However, some products,

perhaps to boost its image of quality, were claiming that the product was purchased and deliveredfrom Hong Kong.
Table 10. Locations of E-commerce shops/sellers offering shark fins and mobulid ray gill plates
Locations

Number of shops
shark
fins

Origin of products

mobulidray gill
platesBeijing

40

naShanghai

30na

Tianjin2

0na

Fujian62

One claimed fins were sourced from Fujian andanother claimed fins were from the Pacific Ocean.

Guangdong

1283

Three claimed shark fins from Indonesia; Sri
Lanka/South Africa and Thailand, respectively.
One claimed gill plates from Sri Lanka, another one
claimed from Indonesia

Guangxi

35

One claimed shark fins from Beihai.
Two claimed shipping from Guangdong.

Hainan

1

0

na

Hubei

1

0

Thailand

Jiangsu

10na

Liaoning

30na

Shandong

11

0

na

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 36

Shanxi

10na

Sichuan10EuropeZhejiang

41

One claimed from Blue Shark, with the image of bonystructured fins.

unknown

70

One claimed from Cameroon (Elephant Shark andOceanic Whitetip Shark), the other claimed from
Canada.

Hong Kong

05

One claimed from the Philippines, the 2nd one claimed
from Hong Kong, Macau and Taiwan. The other threeclaimed from the 2nd shop that sourced from Hong
Kong, Macau and Taiwan.

Note: na – not available.
Several B2C and C2C websites have adopted a No Shark Fin advertisement policy since 2009
(Anon., 2012c).

As a result, only a limited number of shark fin advertisements were found.

However, mobulid ray gill plates were offered on a few websites.
Mobulid ray gill plates were only found to be offered for sale on surveyed B2C and C2C websites,
and were not listed on any of the surveyed B2B websites.

That the majority (83 shops/sellers, 87%)of the observed mobulid ray gill plate shops/sellers were located in Guangdong Province may
indicate that the popularity of mobulid ray gill plates was not yet widespread, and that theconsumption was limited to household preparation of health tonic, not yet as a culinary cuisine
found in restaurants.

The rest of the online mobulid ray gill plate sellers were located in Guangxi(5), Fujian (2) and Zhejiang (1) Provinces, as well as in Hong Kong (5). In contrast, no C2C ecommerce sellers/shops offered shark fins for sale, and only 10% (6 out of 60) of the shops offering
shark fins for sale were found on B2C websites.

The rest (90%) of shark fin e-commerce shops

were B2B shops targeting restaurants and retailers.

This may indicate that the shark fin market inmainland China is still significant enough to support these B2B shops, and that links between
suppliers and buyers were also steady.

None of the available information revealed the true sourceof imports of mobulid ray gill plates available in China, nor the species being sold.

While shark

fins were noted to have been sourced from Asia, Europe, Africa and North America, and to include
species of Blue Shark Prionace glauca, Oceanic Whitetips Shark Carcharhinus longimanus and“Elephant Shark,” such information on source and species was often not provided at all on ecommerce sites, and where it was provided, its authenticity could not be verified.

Some shark fin

sellers in Fujian and Guangxi claimed that their fins came from local provinces or the Pacific Ocean;
it is possible that while these fins were processed locally, they were either harvested by Chinese
flagged vessels or imported.

37 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Market survey
Shark fins
One-hundred and fifty dried food shops from seven cities in mainland China (4), Hong Kong (1)and Taiwan (2) were selected for quantitative market surveys28 (Table 1).

Sixteen managers orowners from shark fin trading/wholesaling/retailing companies in seven cities29 were interviewed aspart of a qualitative survey.

The main shark fin commodities offered for sale in these cities were

processed dried shark fins.

These processed dried fins are easy to store for a long time and had

been processed to such a stage that individual restaurants were capable of preparing it further as a
cooking ingredient.

Although the processed dried shark fins were further sorted into different

categories of commodities based on the species, fin positions, size, grades and supply locations, andfor sale at different prices, there is no unified standard for these categories across different markets
and locations.
The shark fins in the market were classified into different “categories” with different prices basedon properties such as the species, processing locations, “fin positions” (such as dorsal, pectoral andcaudal fins), size and grades of fins (Lin 2010), although some categories of fins could come from
more than one species of shark.

For example, the name used for a given category might refer to aparticular fin position, such as the caudal fin, rather than the species.

Sometimes shark fins of thesame species and same fin positions but in obviously different sizes may be classified as different
categories with different prices.
Other dried seafood, valuable Chinese medicine (such as ginseng) and other dried food (such as
Shiitake mushroom) were also commonly found in shops selling shark fins.

In mainland China,

shark fins were estimated30 to account for 34% and 39%, by volume, of the commodities that wereavailable in the surveyed shops located in Beijing/Shanghai and Guangzhou/Shenzhen, respectively.
Shark fins accounted for a smaller proportion of commodities in shops in Taiwan (21%) and Hong
Kong (18%).

A small number of shops surveyed in Taiwan (20%) and Hong Kong (10%),respectively, which have shark fins accounted for more than 40% of the total commodities in the
shops (Figure 14).

On the other hand, around 50% of shops surveyed in mainland China which

had shark fins accounted for more than 40% of the total commodities in the shops (Figure 14).
28

The seven cities for quantitative interviews were Beijing, Shanghai, Guangzhou, Shenzhen, Hong Kong,
Taipei and Kaohsiung.
29
The seven cities for qualitative interviews were Beijing, Shanghai, Guangzhou, Puqi, Hong Kong, Taipei
and Kaohsiung.
30
The share of shark fin relative to the other commodities in the shops was estimated visually based on the
shelf space of shark fins taken up in the front of shops, but did not include the storage area in the back ofshops.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 38

Figure 14. The estimated share of shark fin relative to the other commodities in the shops
100
80

Less than 19%60

20 to 39%40

40 to 59%
60 to 79%20

80 to 99%
0
TaiwanHong Kong Guangzhou Beijing // Shenzhen Shanghai

Note: The share of shark fin relative to the other commodities in the shops was estimated visually basedon the shelf space of shark fins taken up in the front of shops, but not include the storage area in theback of shops
On average, Beijing and Shanghai shops offered three categories of shark fins for sale.

Hong Kong(3.4) and Guangzhou/Shenzhen (3.3) offered more than three categories of shark fins, and shops in
Taiwan offered 2.5 categories of shark fins for sale.

In total, only eight categories of shark fins were

found in Beijing/Shanghai, many more categories of shark fin were found in Hong Kong (24),
Taiwan (30) and Guangzhou/Shenzhen (46).
In total, nearly 80% of the surveyed shops which sold shark fin offered between two and fivecategories of fins for sale (Figure 16).

In Taiwan, a large percentage (40%) of shops only offered

one category of shark fin for sale, 56% offered between two and five categories of shark fins, and therest (4%) of the shops offered at least six categories of shark fins for sale.

At the same time, Taiwan

was the only surveyed location in which some shops (2%) offered more than 11 categories of sharkfins.

In Hong Kong, all shops provided two to five categories of shark fins for sale (Figure 15).

In

Guangzhou/Shenzhen, only 9% of shops sold one category of fin, 87% of shops offered two to fivecategories of shark fins, with the rest (4%) providing six to ten categories of shark fins.

In Beijing

and Shanghai, 93% of shops offered one to five categories (13% provided only one type) of shark
fins, with the rest (7%) of the shops providing six to ten categories of shark fins (Figure 16).

39 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Figure 15. Number of shark fin categories available in the shops
100

One category
only

80

2‐3 categories
60
4‐5 categories
40
6‐10 categories

20

More than 11
categories

0
TaiwanHong Kong Guangzhou / Beijing /Shenzhen
ShanghaiIn general, stores in mainland China, Hong Kong and Taiwan could not name the corresponding
species for 85% of the shark fin categories sold.

Stores in Taiwan and Guangzhou/Shenzhen

stocked a higher number of shark species, among those fin categories identified to the species level,
than stores from Hong Kong and Beijing/Shanghai.
In contrast to their relative lack of knowledge of species, stores in mainland China, Hong Kong andTaiwan were generally able to differentiate between categories of fins originating from different fin
positions on a shark (e.g., caudal, dorsal or others).
shark fin categories for any fin position.

In total, traders were able to recognize 89% of

Most shark fins on sale were caudal fins (31%) and dorsal

fins (30%).
Qualitative interviewees felt that the production process, from fresh to dried shark fins, was simple
and has little impact on the quality of the final product.

Mainland China, Hong Kong and Taiwan

all have their own processing industries to supply domestic markets.

Around 94% of shark fin re-exported from Hong Kong to mainland China were raw, while 71% of shark fins that Hong Kong
imported from mainland China were processed.

It is possible that most of the processed shark fin

Hong Kong used was processed in mainland China.

Shark fin processing in Hong Kong was either

at a smaller scale or only involved part of the procedure, such as the dehydration step from fresh todried raw fins as well as another drying step before packing.

The steps of soaking, removing

scales, bones and bleaching to make the raw fins into processed fins probably took place in factories
in mainland China (Stan Shea, Bloom Hong Kong, in litt. to Joyce Wu, Jan. 2016).
More than 90% of surveyed shops in Hong Kong, Guangzhou, Shenzhen and Taiwan claimed thatshark fins can be stored for three years or longer after purchase; however, 30% of surveyed shops inBeijing and Shanghai suggested shark fins can only be kept for less than three years after purchase.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 40

According to the survey, stockpiling was happening when shark fin demand was high or stable, or
when demand was on the increase.

During those times, wholesalers and retailers ordered large

amounts of fins at relatively lower prices.

Due to declining restaurant demand, stockpiling is nolonger seen as a good option, but some large companies still have stockpiled inventory left over fromthe past.

A shorter storage life after purchase was found among Beijing and Shanghai shops, andmay be due to a tendency to obtain their shark fin stock from wholesalers in Guangzhou where theproduct may have been held for some time already, rather than directly from processors.
Mainland China Market Overview
Seventy-five stores were surveyed in four cities in mainland China: Guangzhou (30), Shenzhen (15),Beijing (15) and Shanghai (15).

All surveyed stores were wholesalers which usually sell products

to retailers and restaurants, but also provide service to individual consumers.

These stores also

stocked products other than dried shark fins, including dried seafood, other dried foods and highpriced Chinese medicine.
Stores in Guangzhou/Shenzhen stated that their shark fins were obtained from processors inGuangdong Province, and were national-level wholesalers, supplying shark fins to restaurants andlocal wholesalers throughout the whole of mainland China.

The wholesalers in Beijing andShanghai obtained their shark fins from Guangzhou and were only responsible for shark fin
distribution within their cities or provinces.
In-depth qualitative interviews in Puqi revealed that processors in Puqi sourced fresh and frozen
shark fins from trading companies, and sold the processed fins to retailers in the nearby provinces.
The China Shark Industry Report (2013a) stated that processers in Guangdong focused on shark fin
processing, while factories in Puqi could process whole sharks.

Nationwide, wholesalers in China

claimed their shark fins were obtained from processors in Guangdong, and Puqi claimed to process
90% of sharks in mainland China (Sun 2014).

It is possible that compared with the amount ofshark fin processed in Guangdong the amount of shark fin processed in Puqi is much smaller.
Puqi is more famous for other shark products, but not shark fins.
Guangzhou and Shenzhen
Stores in Guangzhou and Shenzhen also provided other dried food and high-price Chinese
medicine for sale.

On average, shark fins accounted for around 39% of commodities, in terms ofvolumes, at the stores in Guangzhou/Shenzhen.

41 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

In total, 46 categories31 (on average, 3.3 per shop) of shark fins were found in the shops inGuangzhou and Shenzhen.

Ya Jian fins (牙揀翅=Blue Shark Fins, see the box below: Somecommonly found shark fin categories) and Pectoral fins (青片翅) were the most common categories
of fins, found in 38% and 29% of shops in Guangzhou and Shenzhen, respectively.

Caudal fins andpelvic fins were the main fin position found in Guangzhou and Shenzhen. Hai Hu fins (海虎翅)were the most expensive fin categories sold in Guangzhou and Shenzhen.

Meanwhile, Jin Shan

fins (金山翅) in Guangzhou and Shenzhen were cheaper than other surveyed cities.
In Guangzhou/Shenzhen and Beijing/Shanghai, there was no knowledge of the species of shark finsstocked for 86% and 94% of categories, respectively.

Stores in Guangzhou/Shenzhen suggested

that their shark fins were from four species, namely Tiger Shark Galeocerdo cuvier, Silky Shark
Carcharhinus falciformis, Blue Shark Prionace glauca, and Oceanic Whitetip Shark Carcharhinus
longimanus.

In terms of knowledge of fin positions, stores in Guangzhou/Shenzhen recognizedcaudal fins (32%) and pelvic fins (29%), but could not identify the rest of their stock to a finposition.
There was limited knowledge about where the shark fins sold in stores in Guangzhou/Shenzhen had
been captured (56%), processed (55%) or imported from (38%).

Of the shark fin pieces that could

be identified to source of capture, processing and import, a range of source locations werearticulated.

They include ones that were captured in Australia (11%), Indonesia (6%), mainland

China (5%), USA (4%) and others; those processed in Australia (8%), Indonesia (6%), the USA(6%), Latin America (5%) and others; and those imported from Indonesia (12%), Australia (8%),
Latin America (7%), USA (6%) and others.

Stores claimed some categories of shark fins were

captured (5%) and processed (6%) in mainland China.
Beijing and Shanghai
In general, the commodity variety in shops in Beijing and Shanghai was lower than shops in othersurveyed cities.

On average, shark fins accounted for 34% of commodities in shops in Beijing andShanghai, but in more than half (54%) of the surveyed stores in Beijing/Shanghai shark finscomprised less than 30% of the stocked commodities.

Furthermore, in about 97% of stores in

Beijing/Shanghai, shark fins represented less than 50% of the visible stocked commodities.
At least eight categories (average three in each shop) of shark fins were found in stores in Beijing
and Shanghai.

Jin Shan Fins (金山翅) and Ya Jian Fins (牙揀翅=Blue Shark fin) were the most

31

“Category” of shark fins refers to the product type of the shark fin available in the shops. It is not equal tospecies of shark, “category” is a combination of species, fin position and even quality or size of shark fin.
Some frequently available categories included Jin Shan, Yan Jian, Hai Hu and Gou (caudal).

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 42

common categories of fins (found in 77% and 73% of stores, respectively) found in surveyed storesin Beijing and Shanghai.

Hai Hu Fin (海虎翅) was the most expensive category of fins sold in

Beijing/Shanghai.
About 94% of shark fin categories in Beijing/Shanghai could not be linked to any species by
shopkeepers, while those that can be recognized (6%) came from only one shark species, Blue Shark
Prionace glauca.

In Beijing and Shanghai, dorsal (41%) and pectoral (24%) fins were mostfrequently sold, and only 1% of shark fin categories were not recognizable by fin positions.
The majority of stores in Beijing/Shanghai had no knowledge of where a product was captured(55%), processed (49%) or imported from (71%).

Where known, only a limited range of locations

were identified: captured in USA (42%) and Spain (3%); processed in Guangdong (37%) and Hong
Kong (14%); and imported from USA (20%) and Hong Kong (11%).

None of the shops inBeijing/Shanghai claimed that their shark fin stock had been captured in mainland China.
Some commonly found shark fin categories
Jin Shan Fins (金山翅)Jin Shan Fin (Gold Mountain Fin) was the Chinese name given to shark fins that were traditionallysourced from the USA and Latin America and imported/transited via San Francisco (Lin, 2010),
which is called “Old Gold Mountain” in the Chinese language, because of its gold mining history.
Jin Shan Fins are valued highly in shark fin markets due to their high quality.

The sanitaryrequirements were considered superior in USA, therefore only shark fin, frozen and dried, whichmeet with the sanitary requirements of USA can enter San Francisco.

As a result, Jin Shan Fins

which are transited or (re)exported from San Francisco have become a symbol of good quality.

Jin

Shan Fins was available in Hong Kong since 1970s when traders in Hong Kong started to importtheir shark fins by air transportation (Kwong, 2013).
Jin Shan Fins were highly visible in most of the surveyed shops in Hong Kong (25 shops, 83%) andBeijing/Shanghai (23 shops, 77%), but not as much in Guangzhou/Shenzhen (6 shops, 13%) andTaiwan (5 shops, 11%).
different sizes and prices.
dorsal fin.

In total, 15 categories of shark fin were named with Jin Shan, but in
Out of the total, 14 categories were Gou Fin, the rest were named as

Twelve categories were found in Hong Kong (USD 103 – 591 /kg), five inGuangdong/Shenzhen (USD 83-209 /kg), three in Taiwan (USD 267 - 431 /kg) and one in
Beijing/Shanghai (USD 206 /kg).

Stores in Hong Kong claimed that Jin Shan Fins were captured

and imported from Latin America (36%), Australia (29%) and USA (24%); but 80% of stores statedthat Jin Shan Fins were processed in Hong Kong.

Most of the stores in Beijing/Shanghai where Jin

Shan fins were available did not know the capture (61%), processing (57%) and export source (57%)

43 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

of the fins.

Some stores, however, claimed that the fins were harvested (39%) and imported (22%)

from USA.

There were no shops in Beijing/Shanghai that claimed Jin Shan Fins were processed inUSA, with some identifying Guangdong (30%) and Hong Kong (13%) as locations where they were
processed.
Only limited numbers of shops in Guangzhou/Shenzhen (6) and Taiwan (5) offered Jin Shan Fins.
In Guangzhou and Shenzhen, stores claimed Jin Shan Fins were harvested in Australia, Indonesia,
Singapore and the Pacific Ocean, but processed locally.

In Taiwan, shops with Jin Shan Fins

claimed that they were processed locally after harvesting in Taiwan, Hong Kong and other oceans.
Clarke found that around 40% of the auctioned fin in early 2000, in terms of weight, in Hong Kongshark fin market comes from 14 shark species (Clarke et al. 2006).

However, more than 50%, byweight, of auctioned shark fins were traded with no specific categories.

Hong Kong shark fin

auctions represent 20% of all Hong Kong imports (Clarke et al. 2004).

Clarke also found that forthe shark fin trade labelling systems there are several taxa contained in one market category or
many market categories are used for one taxon (Clarke et al. 2006). Jin Shan Fin was not one of the
trade categories described in Clarke et al.’s reports published in 2004 and 2006.

In addition to thechallenge of shark fin trade labelling systems described by Clarke et al. (2006), surveys conducted at
different points (auction vs wholesale/retail) along the supply chain could also be a reason for
assigning different trade categories.
Ya Jian Fins (牙揀翅)Ya Jian Fins are the fins of Blue Shark, and were commonly found at stores in mainland China,
Hong Kong and Taiwan.

They were reportedly supplied from Japan, the Philippines, Indonesia,

South Korea, Brazil and several countries in Africa (Lin, 2010).
Water Shark Fins.

In Taiwan, Ya Jian Fins are called

A relatively high percentage of surveyed stores in Beijing/Shanghai (73%, 22),

Hong Kong (67%, 20), Taiwan (51%, 23) and Guangzhou/Shenzhen (38%, 17) offered Ya Jian Fins
for sale.

According to the quantitative survey, Ya Jian Fins are composed mainly of either dorsal

fins (56%) or caudal fins (22%) and pectoral fins (14%). Ya Jian Fins were claimed to be sourced
from fisheries in USA, Latin America and Australia, but also imported from Indonesia and Africa.
Ya Jian Fins were thought to be processed in Hong Kong, Guangdong and other places in mainland
China, Latin America and Australia.

Clarke et al. (2006) found that Ya Jian fin was the mostcommonly found trade category, accounting for 18% of fins auctioned, by weight, in the Hong Kong
market.

After DNA testing, Ya Jian Fin is highly concordant with Blue Shark.

At least sevencategories of Ya Jian Fin can be found, four in Guangdong/Shenzhen (USD 62-123/kg), three in
Taiwan (USD 382-668/kg), one in Hong Kong (USD 124/kg) and one in Beijing/Shanghai (USD
67/kg).

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 44

Gou Fins (勾翅)Gou Fin is the lower parts of caudal fins, regardless of the shark species (Lin, 2010).

However, thesurvey found that caudal fin was not the only part of fins used as Gou Fin. Dorsal fins (32%),
pectoral fins and pelvic fins were also used to make Gou Fins.

Although most of the stores did notknow the shark species for their Gou Fins, some were claimed to be sourced from Tiger Sharks,
Silky Sharks, Blue Sharks, Guitarfish, Great White Sharks, Oceanic Whitetip Sharks and others.
Gou Fins sold in Taiwan often specified the species’s common name, such as “Blue Shark Gou Fins”
or “Silky Shark Gou Fins.”

Lin (2010) suggested that restaurants and hotels tend to purchase more

pelvic and dorsal fins and fewer caudal fins.
the shop premises.

Thus, Gou Fins (caudal fins) commonly remained on

In total, 29 categories of shark fin found in the market survey were named with

Gou Fin, including 14 categories of Jin Shan Gou Fin.

Fourteen found in Guangzhou/Shenzhen(USD 26 - 209/kg), eleven found in Hong Kong (USD 99 - 591/kg), six found in Taiwan (USD 100 –546/kg), and only one found in Beijing/Shanghai (USD 235/kg). Gou fin was also not described as
one of the trade categories by Clarke et al. (2006).
Hai Hu Fin (海虎翅)Hai Hu means “Marine Tiger” in the Chinese language.

Hai Hu Fins are from Dusky Shark

Carcharbinus obscurus harvested from Viet Nam, Indonesia, Australia, Middle East and Pacific
Ocean of South America (Lin, 2010).

Forty-four percent of the Hai Hu fins found in mainland

China, Hong Kong and Taiwan (combined) were claimed to be fins of Tiger Shark, however only 6%
was claimed as being sourced from Dusky Sharks.

Only one category of Hai Hu fin was found, inHong Kong (USD 429/kg), Guangzhou/Shenzhen (USD 247/kg) and Beijing/Shanghai (USD
239/kg), but not in Taiwan.

Clarke et al. (2006) has reported that Hai Hu fin was one of the 14

trade categories and accounted for 1.7% of fins auctioned in the Hong Kong market.

Clarke also

reported that many traders in Hong Kong have associated Tiger Shark with Hai Hu fins.

However,the DNA test found that Hai Hu is concordant with Dusky Shark, but not Tiger Shark.
Hong Kong Market Overview
Thirty shark fin retail outlets in Sai Ying Pun (西營盤) were surveyed.

All of these shops also soldother dried seafood and high-price Chinese medicine, such as Ginseng.

The average volume ofshark fins available in these shops was estimated to be less than 18%.

In 96% of those shops whichsell shark fins, the fins accounted for less than 30% of commodities seen in the shops.

Most of thecustomers were local residents; there were very few buyers from mainland China, and restaurants
and caterers in Hong Kong tend to make their orders directly from either trading companies orprocessors.

45 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

On average, more than three categories (3.4) of shark fins commodities were available in the shops,
and in total 24 categories were found.

Around 83% and 67% of surveyed shops in Hong Kong

carried Jin Shan Fins (金山翅) and Ya Jian Fins (牙揀翅=Blue Shark fins), respectively, in stock.
Caudal and dorsal fins were the fin position that were most prevalent in Hong Kong. Jin Shan Fins
(金山翅) and Hai Hu Fins (海虎翅) were the most expensive commonly found shark fin categories
offered.

A rarely found shark fin category Gu Pian Fin, supposed to be fins from Great

Hammerhead Shark Shpyrna mokarran was found in Hong Kong.

It cost USD 134/kg on average.

In Hong Kong, 82% of shark fins categories were sourced from unknown species.

This may be due

to fact that the names used for the product categories are not associated with species names, andperhaps also because there are no active shark fisheries in Hong Kong.

Of the categories where

species could be identified, mainly Tiger Sharks (14%) and Blue Sharks (2%) were recognized.

In

Hong Kong, as in Taiwan, dorsal (39%) and caudal (41%) fins were the most commonly sold fin
positions.
Surveyed stores in Hong Kong tended to claim that most of their shark fins were processed
domestically (76%), but some were processed in Latin America (11%), mainland China (8%), USA(6%), Australia (4%) and others.

This differed with the reported capture and import locations.

Shops in Hong Kong claimed their shark fins were captured in the USA (30%), Latin America(30%), Australia (19%), Mexico (16%) and others.

Imports were sourced from Latin America(30%), USA (27%), Australia (20%), Mexico (16%), Spain (10%), Africa (8%) and others (according
to shopkeepers).

Compared with stores in Taiwan and mainland China, very few shops in Hong

Kong were unable to name the location of capture, processing and import source of their shark fin
stock.

However, as the veracity of this information was not confirmed, this should not beinterpreted to mean that the shops in Hong Kong are necessarily able to provide more accurate
source location information.
Taiwan Market Overview
Forty-five dried food shops were surveyed in Taipei (30) and Kaohsiung (15). These werewholesalers, but they also sell to individual customers.

These shops provided various commodities

for sale, including different types of dried seafood, other dried food (such as Shiitake mushroom)and some valuable Chinese medicine (such as ginseng).

On average, shark fins accounted for 21%of the commodities in the shops.

In 84% of the shops, shark fins were less than 30% of thecommodities sold in the shops.

In 95% of the shops, shark fins made up less than 50% of thecommodities sold in the shops.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 46

In Taiwan shops, on average, around 30 in total and 2.5 categories per shop of shark fins could be
identified. Blue Shark fins (水勾翅) (51%) and Silky Shark caudal fins (黑鯊勾翅) (36%) were themain categories of shark fins sold in Taiwan. Jin Shan Fins (金山翅) were the most expensive
shark fin categories commonly found in Taiwan.

In Taiwan, there were some other expensive but

rarely available shark fin categories, such as Long Wen Fin (龍 翅).
be sourced from guitarfish (Rhinobatidae).
costing around USD 618 – 1,392/kg.

Long Wen Fin is supposed toThree categories of Long Wen Fin found in Taiwan,

In general, shark fin prices in Taiwan were higher than thosein Hong Kong and China.
In Taiwan, stores had no knowledge of the species for 76% of their shark fin categories.

The rest

came from Blue Shark (9%), Silky Shark (6%), Guitarfish (4%) and Oceanic Whitetip Shark (3%).
In Taiwan, dorsal (52%) and caudal (35%) fins were the fin positions most frequently identified.
High percentages of shark fins available in Taiwan were processed (81%) and obtained (61%)
domestically.

Stores in Taiwan claimed that their shark fins were obtained from the processing

plants in Kaohsiung, and sold mostly to restaurants and caterers.

Out of the total, 44% of shark fin

categories found in the stores of Taiwan were not identified to capture locations, and the rest were
captured in Taiwan (31%), Latin America (11%), Africa (7%) and others.
Price of shark fins
On average, Silky Shark caudal fins (USD 380/kg), Blue Shark caudal fins (USD 371/kg) and Jin
Shan Fins (USD 339/kg) were the most expensive categories of shark fins commonly found in thissurvey.

Silky Shark caudal fins and Blue Shark caudal fins were only available in Taiwan andGuangzhou/Shenzhen, and not sold in Hong Kong, Beijing and Shanghai.
Jin Shan Fin was most expensive in Hong Kong (USD 489/kg), followed by in Taiwan (USD 431/kg),
Beijing/Shanghai (USD 206/kg) and Guangzhou/Shenzhen (USD 151/kg). Jin Shan fin was themost readily available fin, and could be found in 83% of surveyed stores in Hong Kong, 77% of
surveyed stores in Beijing/Shanghai, 13% of stores in Guangzhou/Shenzhen and 11% of stores in
Taiwan.

Gou Fins were also available in all markets.

The cost of Gou Fins (multiple species) werethe most expensive in Taiwan (USD 414/kg), followed by Guangzhou/Shenzhen (USD 161/kg),
Beijing/Shanghai (USD 148/kg) and Hong Kong (USD 129/kg).
On average, the upper prices of shark fins were higher in Taiwan (USD 28 – 1,391/kg) and Hong
Kong (USD 99 - 591/kg) and lower in mainland China (USD 26 - 419/kg).

There were a few

exceptions, however, where a few categories of shark fins both available both in Hong Kong andmainland China were more expensive in mainland China than in Hong Kong.

The price of shark

47 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

fin is decided by many criteria, including species, size and fin position.

Long Wen Fins found in

Taiwan were expensive (USD 1,391/kg, USD 835/kg, and USD 618/kg), but large size Blue Shark fin
was also expensive (USD 668/kg).
Shopkeepers claimed that fin position (61%) and grade (45%) of shark fins were the first two criteriathat most determined the price of shark fins.
important criteria.

The species of shark was considered the third most

In Beijing and Shanghai, species were not an important factor in the pricecharged.

However, fin positions and species, and not grades, influenced prices in Guangzhou andShenzhen.

In Hong Kong, in addition to the fin positions, grades and species, other characteristics

such as size, export location and fineness of shark fins were also criteria that affected the pricecharged.
The price of shark fins in different cities was not only based on the cost of purchasing the stock, butalso on the cost for running the business, consumer preferences for shark fin categories, available
quantities and business competition.

The survey found that, on average, stores in mainland China

had higher percentages of shark fin products displayed on their premises (34% in Beijing/Shanghai
and 39% in Guangzhou/Shenzhen) than did those in Hong Kong (18%) and Taiwan (21%).

This

may indicate that stores in mainland China relied more heavily on shark fins for revenue generationand had larger volumes of stock displayed than those in Taiwan and Hong Kong.

It could also

explain why the price of shark fins was, in general, lower in mainland China than in Hong Kong andTaiwan.
Overall, shopkeepers were not able to recognize 85% of shark fins categories by species. However,
the majority (89%) of shark fins categories could be distinguished by fin positions. Gou Fins accountfor 21% of all categories of fins available in mainland China, Hong Kong and Taiwan, and are also
reported to be the most frequently (31%) sold in physical markets in mainland China, Hong Kong
and Taiwan.

Gou Fins from Silky Shark and Blue Shark were the two most expensive categories ofshark fins, and the Jin Shan Gou Fins ranked third.
It was said that dorsal and pectoral fins were mostly used by restaurants and hotels, while caudal
fins were more visible in the wholesale and retail premises (Lin, 2010).
consumers were more likely to only know about Jin Shan Gou Fins.

Lin (2010) also found that

Physical market surveys

revealed that “fin position” is the most important criteria for the price difference in mainland
China, Hong Kong and Taiwan.

This might be due to the high presence of Gou Fins, and thehigher demand for Gou Fins from consumers.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 48

There was high visibility of Jin Shan Fins in stores in Hong Kong (83%), Beijing/Shanghai (77%),
Guangzhou/Shenzhen (13%) and Taiwan (11%).

While Customs data indicate that imports from

USA only accounted for 0.12%, 2.3% and 0.05% of total imports in mainland China, Hong Kong
and Taiwan, respectively, shopkeepers identified 30% (Hong Kong) and 40% (Beijing/Shanghai) of
shark fin categories as captured in the USA. It is therefore likely that the information regarding theorigin and transit countries/territories of shark fins at the storefront is not accurate, and thatstatements by shopkeepers were made to fulfil the preference of consumers.
Suppliers
Based on the quantitative survey, stores in Taiwan claimed that most (67%) of their shark fin
categories were sourced from within Taiwan, with only limited categories of shark fin being supplied
from Latin America (3%), Hong Kong (2%) and Australia (1%).

A substantial 28% of shark fin

categories had no information where the product was supplied from.

In contrast, only 1% of shark

fin categories in Hong Kong did not have information, based on the response of shopkeepers but
not labelling, about where the product was supplied from.

Shark fins in Hong Kong were

imported from Latin America (30%), USA (27%), Australia (20%), Mexico (16%), Spain (10%),Africa (8%), Indonesia (4%) and others (according to shopkeepers).

Most (62% in

Beijing/Shanghai and 38% in Guangzhou/Shenzhen) shark fin categories in mainland China did nothave information about the products’ import source.

In Beijing and Shanghai, 20% and 11% ofshark fin categories were imported from USA and Hong Kong, respectively.

In Guangzhou andShenzhen, shark fin categories were imported from Indonesia (12%), Australia (8%), Latin America(7%), USA (6%), Spain (3%) and Africa (3%).
Capture Areas
Similar to import information, only 2% of shark fin categories in Hong Kong did not haveinformation on the capture location, but most shark fin categories in Taiwan (44%) and mainland
China (55%) did not have such information available.

Stores in Hong Kong claimed their shark

fins, in terms of categories, were captured in the USA (30%), Latin America (30%), Australia (19%),
Mexico (16%) and others.

Shark fins, in terms of categories, in Taiwan were captured in Taiwan(31%), Latin America (11%), Africa (7%) and others.
categories were captured in the USA (42%).

In Beijing and Shanghai, 42% shark fin

Although most of stores in Guangzhou and Shenzhenalso did not state the capture areas for their shark fins, the information that was available showed
the shark fins on offer in these two cities were captured from a diversity of areas, such as Australia(11%), Indonesia (1%), mainland China (5%) and the USA (4%).

49 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Processing Areas
Most stores in mainland China were also not aware about where shark fins were processed, but the
majority of stores in Hong Kong (100%) and Taiwan (88%) were able to provide this information.
There were 81% and 76% of shark fin categories in Taiwan and Hong Kong, respectively, which were
processed locally.

Some stores in Hong Kong also claimed that their fins were processed in Latin

America (11%), mainland China (8%), USA (6%), Australia (4%) and Africa (3%).

Shark fins, interms of categories, offered in Guangzhou and Shenzhen were processed in Australia (8%), USA(6%), Indonesia (6%), Latin America (5%), Africa (3%) and mainland China (6%), but not in Hong
Kong.

Stores in Beijing and Shanghai stated that their shark fins, in terms of categories, were

processed in Guangdong (37%) and Hong Kong (14%).

It is possible that shark fin processing,from frozen/fresh fins to processed fin, takes place in multiple locations, such as Hong Kong andGuangdong.

Hong Kong is at least involved in the sun-drying step to dehydrate the fresh fins to

the dried raw fin, as well as another drying step before packaging (Stan Shea, Bloom Hong Kong, inlitt. to Joyce Wu, Jan. 2016).
Mobulid ray gill plates
None of the surveyed stores in Taiwan were found to offer mobulid ray gill plates for sale, and only
three stores in Beijing and Shanghai supplied mobulid ray gill plates.

Thirteen stores in Hong

Kong and nine stores in Guangzhou/Shenzhen were found to offer mobulid ray gill plates for sale.
In 92% of the 13 stores in Hong Kong, shopkeepers claimed that the gill plates were sourced from 魔鬼魚32(could be Devil Rays, Mobula spp.); these gill plates were sold for USD 138/kg on average.
The rest (8%) of the stores in Hong Kong sold gill plates at an average cost of USD 278/kg, but did
not recognize the species.

Mobulid ray gill plates were categorized into more categories for sale in

Guangzhou than Hong Kong.

The nine stores in Guangzhou and Shenzhen provided Xu gill plates(徐鱼腮) (89%, USD 87/kg), Jiao Yan gill plates (角燕鱼腮) (11%, USD 350/kg), and Top-Level Huagill plates (顶级花腮) (11%, USD 156/kg) as well as small gill plates (小鱼腮) (11%, USD 73/kg).
All three stores in Beijing and Shanghai did not categorize their gill plates, and charged USD 125/kg.
In addition to the quantitative survey, the qualitative survey found only one interviewee in
Guangzhou which sold mobulid ray gill plates at the retail level.

Other interviewees who did notsell mobulid ray gill plates considered it to be a low-price tonic ingredient.

32

The commodity name was either provided verbally by shopkeepers or written in Chinese. The genus andspecies of the commodity cannot be verified without further investigation.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 50

Based on the market survey and observations from e-commerce websites, the market for mobulid
ray gill plates was predominantly found in southern China.

E-commerce shops/sellers tend tolocate close to their consumers to provide timely and cost effective service.

The majority (86%) of

the e-commerce shops or sellers advertising gill plates were located in Guangdong.

The productvariety and prices charged for mobulid ray gill plates in the Guangzhou physical market were higher
than those in Beijing, Shanghai and Hong Kong.

This indicates that Guangdong was both thecentre of the trade and a more mature market for mobulid ray gill plates.

This finding also

matched with an earlier mobulid ray gill plate survey in 2014 (Heinrichs, 2014).
Although e-commerce sellers for mobulid ray gill plates in Hong Kong tend to target consumers insouthern China, most consumers of the processed dried shark fins from retail outlets in Hong Kong
were local residents, and not tourists from China.

51 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

DISCUSSION AND CONCLUSIONSThe Customs data showed that the legal import and (re)export of shark fins decreased significantly
in mainland China and Hong Kong in recently years.

Viet Nam replaced mainland China as the

major destination for shark fins (re)exported from Hong Kong in 2010, 2013 and 2014.

Marketsurveys in different cities in mainland China, Hong Kong and Taiwan also indicated that shark fin
availability is limited, wholesalers and retailers tend to lower their inventory to respond to fastchanges in the markets.
Seizure cases of shark fin, frozen seafood and others in mainland China could indicate that someshark fins (re)exported to Viet Nam from Hong Kong or elsewhere might be (re)exported tomainland China.

This case, in addition to the Hong Kong (re)export data, had re-emphasized thatthe shark fin imports recorded by the Customs of mainland China were under-reported.

The

variety of processed dried shark fins available in the dry food markets in mainland China, Hong
Kong and Taiwan indicated that the markets are still in good shape but not dwindling.
In general, the information and trade data for manta ray gill plate are extremely limited.

However,advertisements found over the e-commerce websites in mainland China and the price variation fordifferent categories of gill plates indicate that there is a risk that the demand for mobulid ray gillplates has increased, since the number of observed e-commerce sellers increased significantly from30 shops in 2013 to 90 in 2015.
As expected, there were no records (UNEP-WCMC CITES data) of trade in any CITES listed
mobulid rays between 2003 and 2013, the listings did not come in to effect until 14th September
2014.

Over the same period, Hong Kong reported 90% (6,933.4 kg) of all trade in CITES-listed

shark species for shark fins (the global total reported over this period was 7,720.7 kg).

Basking

Shark was the only species reported, and Norway was the only country that Hong Kong reported
imports from.

Norway, however, had only reported 12% of the Basking Shark fins that Hong Kong

imported (805.6 kg in 2005 and 2008).

Hong Kong also (re)exported 9 kg of Basking Shark fins to

Malaysia in 2006, but this trade was not reported by Malaysia.
It may be too early to conclude that these data discrepancies indicate that the trade was illegal.
They do, however, raise the issue of inconsistent data management and trade monitoring of importsand (re)exports of shark products in Hong Kong, even though it has reported a higher frequency
and volume of trade than its trade partners.

The data were especially surprising given that Hong

Kong handles around 50% of the global shark fins trade (Clarke 2004), and imports fins from more

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 52

than a hundred countries/territories, and yet only reported trade in a single CITES-listed species,
with two countries, over the entire ten-year period.

Improved monitoring of the shark fin tradefor CITES compliance is needed, including the identification of CITES-listed shark species and theissuing of appropriate CITES documents for trade. Such improvements are necessary not only inHong Kong but also among at least the top 20 shark fin trading countries/territories.

Mobulid ray gill plates
There appears to be no demand for mobulid ray gill plates in Taiwan, and only limited demand in
Beijing and Shanghai.

Guangzhou, in contrast, seems to be at the centre of the trade for mobulid

ray gill plates, with a more diverse selection and a wider range of prices exhibited. Guangzhou isfurthermore the location for the majority (87%) of the C2C e-commerce shops advertising the saleof gill plates.

While there were some mobulid ray gill plates for sale in Hong Kong, local demand

for these was likely to be limited and could well be serving consumer demand in Guangdong andother places in mainland China; there were only five sellers located in Hong Kong, and three of
those provided “shopping services” to mainland China.
Most of the e-commerce in mobulid ray gill plates is marketed directly to consumers; the majority ofthe observed advertisements were posted on C2C websites, and there were no sellers found among
the surveyed B2B websites.

It therefore seems likely that the popularity of gill plates is limited tohousehold consumption, as opposed to restaurants, hotels or caterers.

Information found throughonline searches showed that most of the key messaging for mobulid ray gill plates focuses on its use
as an ingredient for tonic, rather than as a delicacy.

Information was available on how to prepareand cook mobulid ray gill plates, but no information was found about where and which restaurants
and/or hotels serve mobulid ray gill plate dishes.

An interviewed trader also commented that themobulid ray gill plates were a tonic ingredient.

Although mobulid ray gill plates were found to be

traded by shark fin traders (Hilton 2014), it is not known if mobulid ray gill plate sales will replace
profits from shark fins sales.

The market survey showed that unit prices for mobulid ray gill plates(USD 87–350) and commonly available shark fins (USD 85–380) were similar; however, some rarely
available shark fin can fetch as much as USD 1,392 per kg and the scale of the market for shark finsis currently much larger and broader.
fin are quite different.

The drivers for demand for mobulid ray gill plate and shark

Shark fins are consumed as a symbol of social status throughout the wholeof mainland China, Hong Kong and Taiwan, on the other hand, mobulid ray gill plates does notappear to be associated with social status, and is not used for gifting to others.
gill plates are considered a tonic and mainly consumed in southern China.

The mobulid ray

Furthermore, therecent focus on shark conservation and anti-corruption concerns has driven down the market for
shark fins but has not affected the market for mobulid ray gill plates.

53 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

There was no capture, import/export or other documented data to estimate the scale of the mobulid
ray gill plates market in mainland China.

A repeated physical market survey in 2013-2014 foundthe mobulid ray gill plates available in Guangzhou had doubled, compared with the survey in 2011
(Whitcraft et al. 2014).

An online survey in 2013 stated that 30 online sellers offered mobulid ray

gill plates for sale (Whitcraft et. al. 2014).

The current study found 90 sellers on the same C2C e-commerce website offering mobulid ray gill plates for sale, as well as a further six shops on a B2C ecommerce website.

With these limited data, it is difficult to conclude how much the market in

Guangzhou or southern China has expanded since 2013.

However, there is a risk that the demand

for mobulid ray gill plates has increased, given the number of observed e-commerce sellers
increased significantly (from 30 to 90 shops). Furthermore, because the cost of expansion to other
cities and regions in mainland China via e-commerce enterprises is low, there is the risk that gillplates will be increasingly marketed in other locations.

The continuous expansion of trade ofmobulid ray gill plates will put heavy pressure on mobulid ray populations which have very low
reproduction rates and are experiencing unsustainable fishing globally (Dulvy et al. 2014).
To ensure effective monitoring of trade in CITES-listed species, e-commerce sellers should be
required to comply with all the rules/regulations that apply for physical markets.

For CITES-listed

species, this means a requirement for importers and (re)exporter, as well as domestic sellers fromonline or physical markets, to provide evidence that their products were legally sourced.

Without

such documentation, the sale of products from CITES-listed species, including mobulid ray gillplates, on e-commerce websites should be prohibited (CITES AC28 Doc. 17.1.1 Annex 3., 2015).
Mainland China requires valid CITES export and import permits for the legal importation of
CITES-listed shark and manta ray species and their products.

The management and registration of

pre-Convention stocks of shark and manta ray products in mainland China is under development(2015d).

All requirements for import, (re)export and domestic trade in CITES-listed species must

apply not only to the premises in the physical markets but also to the e-commerce shops, if the tradein CITES-listed shark and mobulid ray species is to be effectively monitored.
The demand for mobulid ray gill plates is likely to be all from the international trade, but the lack of
specific Custom codes means the trade cannot be tracked, and which is worrying given thevulnerability of the species (CITES CoP 16 Proposal 46 Rev. 2).

Shark fins
In contrast to mobulid ray gill plates, 90% of e-commerce shops advertising shark fins were foundon B2B websites, only six shops were found to offer shark fins for sale on a B2C website, and noneon C2C websites.

This is due to the “No Shark Fin” policies of certain websites.

It is important

for website platform managers to continue strictly to monitor all of their e-commerce websites.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 54

In general, the physical markets selling shark fin in mainland China, Hong Kong and Taiwan
showed distinct characteristics.

Stores in mainland China displayed a high percentage of shark fin(39% for Guangzhou/Shenzhen and 34% for Beijing/Shanghai) among the commodities on theirpremises and offered a medium to high diversity of shark fin categories for sale (an average of 3
categories for Beijing/Shanghai and 3.3 categories for Guangzhou/Shenzhen).

Stores in Hong

Kong also provided a high diversity of shark fins categories (3.4), but shark fin was much lessprevalent (18%) among the offered commodities.

Shops in Taiwan had both a low percentage(21%) of shark fin commodities and low diversity of shark fin categories (2.5).

However, in termsof the total number of shark fin categories that can be found in different markets, only eightcategories of shark fins were found in Beijing/Shanghai. A greater number of categories of shark fin
were found in Hong Kong (24), Taiwan (30) and Guangzhou/Shenzhen (46).
Although 40% of stores in Taiwan only offered one type of shark fin, 4% displayed more than 5
categories of shark fin for sale.

While none of the shops in Hong Kong offered only a single type ofshark fin for sale, neither did any offer more than five categories.

In mainland China, only 9-13%

of shops offered only one type of shark fin, while 4-7% shops offered more than five categories ofshark fin for sale.
This indicated that most of the shops in Taiwan sold similar commodity categories of shark fin, with
only a few of them selling more diverse and less replicated shark fin categories.

However, mostshops in Guangzhou, Shenzhen and Hong Kong offered more diverse and less replicated shark fin
categories.

The shops in Beijing and Shanghai were somewhat in between.

More than 90% of the surveyed stores in Taiwan, Hong Kong and Guangzhou/Shenzhen claimed
that shark fins can be stored for at least three years after purchase.

Only 70% of stores in

Beijing/Shanghai made the same claim, with the rest claiming that, after purchase, shark fins canonly be stored for two years.

This difference is likely to be due to the sourcing of shark fins sold in

Beijing and Shanghai from wholesalers in Guangzhou/Shenzhen, where the fins may already havebeen stored for some time, rather than directly from processors, thereby limiting the remaining
shelf life of the fins once they reach the retailers in Beijing/Shanghai.
Qualitative surveys also confirmed that stockpiling tended to occur in the past, when market
prospects were more optimistic, but such behaviour has declined in tandem with the declining
demand of recent years.

Most of the stores are only placing new orders when their inventory is

running out, to avoid the uncertainty of the market.

55 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Any stockpiling of shark fins which may have occurred after the launch of the anti-corruption
policy in China may not happen as the processed dried fins at the retail or wholesale level in the
consumption market, but could instead happen as the raw frozen fins in the shark fisheries
countries.

For example, a 2012 report claimed that the owners of fishing vessels piled up shark finsin their freezers but did not sell those due to declining market demand and decreasing price (Lu2012).

Also, the observed increase in shark fin imports in recent years in Taiwan may indicate thatshark fin stockpiling has happened as raw frozen fins in the shark fisheries entity rather than as theprocessed dried fins at the consumption side.
Mainland China’s trade in shark fins, which included imports of shark fins from 36
countries/territories and (re)exports to nine countries/territories, declined between 2005 and 2014.
For both import and (re)export volumes, trade in the first four years (2005-2008) accounted for 90%of the ten-year total imports (11,727 t) and (re)exports (4,143 t).

Mainland China imported shark

fins from a progressively smaller share of countries, down to 11 between 2009 and 2014 from a totalof 36 between 2005 and 2008.

Clarke (2004) reported that mainland China imported shark finsfrom, on average, 21 countries/territories each year between 1996 and 2002.

This figure was much

lower than for Hong Kong, which imported shark fins from more than 80 countries each year from1996 to 2002.

Mainland China imported 29% (3,350 t) and 5% (585 t) of their shark fins from

Taiwan and Hong Kong, respectively.

Taiwan and Hong Kong ranked 1st and 8th amongst exportersof shark fin to mainland China from 2005 to 2014.

However, the imports of shark fins from

Taiwan almost all occurred in the first five years (2005-2009), while the imports from Hong Kongrun throughout the ten-year period.

Hong Kong Customs data suggest that mainland China hadsignificantly under-reported their shark fin imports, however this is probably due to the practice of
excluding those commodities intended “for processing”.

Mainland China’s total shark fin imports

increased from 11,727 t to 38,270 t between 2005 and 2014, if Hong Kong’s (re)export figure wasused to adjust mainland China’s import record (Figure 9 and Annex 7).
Market surveys in mainland China found that Jin Shan Fin can be found in 77% of shops inBeijing/Shanghai.

Jin Shan Fin is so named to demonstrate that it was transited/exported from San

Francisco, with the connotations of better processing quality in or before entering into San
Francisco and the implication of better quality and a longer storage time.

The observed presenceof these fins in stores contrasted with official import figures, where only 9% (1,060 t)33 of shark finswere imported from the USA, Canada and Latin America, i.e. those from which they mightreasonably have expected to have been sent to San Francisco for processing or transit.

Some storesin Hong Kong claimed that Jin Shan Fins were imported from Australia and processed locally.

33

0.12% (14 t) from the US, 0.38% (44 t) from Canada, and 8.55% (1,002 t) from Latin America

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 56

Hong Kong’s Customs data have recorded shark fins imported from Australia, however it seems
unlikely that shark fins originally from Australia would have transited through San Francisco.

It ispossible that the term “Jin Shan Fin” is presently used to refer to one category of shark fin, and is nolonger related to the origin or processing location.
The high visibility of Jin Shan Fins in the market, and its discrepancy with official import volumes,
is not only indicative of consumer behaviour that has little basis in rationality, but also reveals a
problem with the mislabelling and overpricing of shark fin products.

At the same time,

information on the species and origin of shark fin were concealed under the category of Jin Shan Fin
and further resulted in the challenge of understanding and tracking them to sustainable sources.
Indeed, Jin Shan Fins were the most expensive category of fins in Hong Kong and the second mostexpensive in Beijing/Shanghai for commonly found shark fin categories.
Hong Kong’s annual imports and (re)exports of shark fins were relatively stable in the early years,
but also experienced a large decrease in 2011 and 2012.

Hong Kong imported shark fins from 115

countries/territories and exported those to 31 countries/territories.

In total, Hong Kong only

imported 16,659 t (19%) of shark fins sourced from Canada, USA and Latin America (i.e. those withthe likelihood of being transited in San Francisco and, thus, being entitled to use the name of the
popular Jin Shan Fins).

However, the high proportion of Jin Shan Fin observed in the surveyed

stores in Hong Kong (83%) did not comfortably match with the low import volume of shark fins(potentially) transited via San Francisco.

Although the likelihood of mislabelling does notnecessarily violate any import and (re)export regulations, it is good practice to ensure properlabelling of products, with species and origin, at all points along the trade chain.

This would also

ensure that consumers are not misled and well-informed when they purchase shark fin products.
At the same time, appropriate labelling will also facilitate the monitoring and tracking of species use
and origin, as well as further help to estimate the sustainability of used shark species. A ten year
global sharks and rays conservation strategy has pointed out that responsible trade is one of the key
to reverse the trend of shark and ray decline (Brautigam et al. 2015). Implementing CITES
effectively, collecting and reporting accurate trade information, adopting an adequate traceability
system, as well as implementing FAO Responsible Trade Guidelines are the essential elements toreach the goal of responsible trade.
Hong Kong’s (re)exports to mainland China decreased significantly in 2009 and 2010, but this wasoffset by steady increases in (re)exports from Hong Kong to Taiwan from 2007 to 2010. (Re)exports
to Taiwan experienced a further significant increase in 2011, before returning to earlier levels in
2012-13. (Re)exports from Hong Kong to some other neighbouring countries/territories, including
Viet Nam, Singapore and Macau, also increased sharply in 2009.

This suggests a shift in

57 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

(re)exports from mainland China to Viet Nam, which is especially evident in 2010 trade figures.
The increased (re)export to Singapore and Macau in 2009 did not persist, except for an increase in2012.
2009 appears to be the turning year for shark fins trade in mainland China (Figure 9).

That year,

there was a significant reduction of (re)export from Hong Kong to mainland China and Viet Nam
became an alternate destination for Hong Kong’s (re)exports of large quantities of previously
imported shark fins.

The shark fin retained in mainland China (adjusted with Hong Kong’s exportdata) dropped from 3,438 t in 2009 to 942 t in 2010.

On the other hand, the shark fin (adjusted

and factored) retained in Hong Kong were around 889 t in 2009 and increased to 1,048 t in 2010.
This indicated that Hong Kong was outpacing mainland China in retaining more shark fins since2009.
This is inconsistent with the conclusion that mainland China is the world’s foremost shark fin
consumer market (Dent & Clarke, 2015).

The consumption of shark fin in mainland China could

be much higher than estimated here through supply from its own fleets, unrecorded trade, such as
e-commerce, tourist souvenirs and smuggling.
Recent events in China that have impacted shark fin trade
There are many possible actions that, individually or in combination, can influence the amount ofconsumer market-based trade in shark fin at any given time, whether it be through influencing
consumer choice, impacting the availability of product at restaurants/hotels, changing carriage
policies within the transportation industry, or establishing regulations. Some recent actions include:A Chinese lawmaker, Ding Liguo (丁立國), deputy to the National People's Congress,
proposed in March 2011 that the country's top legislature should ban the trade of shark fin(Ma, 2011).



A Hong Kong reporter visited Puqi in Zhejiang Province in May 2011, one of the largest shark
processing centres in China, and exposed Puqi’s role in China’s shark processing business.

Wenzhou in mainland China launched a more detailed anti-corruption policy in July 2012, to
specify the ban of shark fin, abalone, Liaoning sea cucumber and others in the government
banquets (Anon. 2012a).

Mainland China launched an anti-corruption policy (Eight Rules & Six Bans) on 4th
December 2012 to restrict the spending of public money on luxury banquets (Anon. 2013c).

Mainland China’s anti-corruption policy (National Reception Policy for Party andGovernment Authorities) was advanced at the end of 2013, with more details such as the banof shark fin, birds nest and protected wildlife, including at government banquets (Anon.
2013d).

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 58

Analysis of Hong Kong’s Customs data, after they were adjusted and factored for water content,
shows that Hong Kong’s retained supply of shark fins progressively increased from 2005, peaked in2011, and then decreased in 2012 and 2013 before appearing to stabilize in 2014.

The retention of

shark fin (adjusted and factored) in Hong Kong in 2014 was 25% lower than that in 2009.

The

peak in 2011 was due to slight increases in imports with concurrent significant decreases in(re)exports.
retained.

Significant declines in imports in 2012 and 2013 reduced the amount of shark fin

In 2014, Hong Kong’s import and (re)export of shark fins (adjusted and factored) did

not exhibit any obvious changes from the volumes reported in 2013.
Interviews with traders suggest that most consumers of processed dried shark fins in Hong Kong
were local residents rather than tourists or parallel traders34 from mainland China.

There aregood independent data to show that shark fin consumption in Hong Kong has been in decline.

A

consumer survey conducted by a university in 2014 showed that shark fin consumption in Hong
Kong at wedding banquets and during the Chinese Lunar New Year had decreased by around 20%,compared to 2009 levels (Anon., 2015b).

Because these data only indicate shark fin consumption

levels in 2009 and 2014, and not in the intervening years, it is not clear if shark fin consumption had
gone through a similar increase and decrease as the pattern of retention reflects.
For a place like Hong Kong that almost has no shark fisheries, the import minus re-export(=retention) can serve as a proxy for domestic consumption.
storage time is at least three years.

Because of the processed shark fin

A three-year moving average based on the annual retention in

Hong Kong was calculated to show larger-scale trends in annual consumption in Hong Kong
(Figure 16).

This moving pattern still showed the increase from 2009 to 2012, followed with a slow

decline in 2013 and 2014.

34

Residents from Shenzhen and Hong Kong purchase sought after commodities in Hong Kong to bring themto Shenzhen for sale. http://www.scmp.com/topics/parallel‐trading

59 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Figure 16. Hong Kong shark fin import, (re)export, retention and three-year moving average(t), 2005-2014
12,00010,000
8,000
6,000
4,000
2,000
‐
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
retention

import(re)export

moving average

Source: Hong Kong Customs data, 2005-2014
Hong Kong’s (re)exports to mainland China declined just as trade with various other neighbouring
countries/territories increased, including Viet Nam, Singapore, Macau and Taiwan.

Therefore, one

possible explanation for the shift in trade between Hong Kong and mainland China is that the trade
may have simply been directed to a transit point elsewhere, before being re-directed to mainland
China.

Hence, the declining trends in trade between the two may not truly represent an overall

reduction in imports to mainland China, and shark fin consumption in mainland China may nothave changed as much as the Hong Kong-China trade seems to suggest.
Viet Nam has replaced mainland China as the largest importer of Hong Kong’s sea cucumber
exports since 2004 (To and Shea 2012) and, while the reason behind a change in trade routes may bedifferent for sea cucumbers and shark fins, a similar consignment route is evident.

A group ofcompanies, based in Hong Kong and Shenzhen, were specialized to handle shipments anddocuments for the transport of commodities from Hong Kong to mainland China.

These

companies used to ship commodities directly between Hong Kong and mainland China, but –according to companies interviewed for this research – increasing volumes of cargo are now beingtransported via Viet Nam.

Cargos from around the world could be shipped to Viet Nam directlyor via Hong Kong, and then transported from Viet Nam to Guangxi in mainland China by land via
unregulated or less well-regulated border points.

Phone interviews revealed that, after cargoarrives in Guangxi, air transportation can be arranged to anywhere in mainland China.

Thistransport route could not only avoid import tariffs and VAT from mainland China, but also othercomplex paperwork and consignment inspections that may be required for high profile products
such as shark fins.

The cases of smuggled shark fin, foreign sourced seafood and “zombie” beef (orrotting meat) revealed that large amounts of import tariffs (one to two thousand Chinese Yuan forevery metric tonnes of commodities) can be saved if products are imported into mainland China via

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 60

the border of Viet Nam and Guangxi (Lee 2015 and Lau 2015).

The moving of commodities fromone side of the border to the other is also efficient, product volumes as high as 35 t cargo can betransferred across the border within two hours by dozens of locals (Lee, 2015).
A news report in 2013 claimed that high priced frozen seafood arrived in mainland China throughthe border of Guangxi and Viet Nam (Lin et al. 2013).

Around one to two thousand metric tonnesof expensive frozen seafood arrived Guangzhou daily.
A decades-old frozen beef scandal in 2015 also revealed the smuggling route between Viet Nam andmainland China (Lau, 2015 and Lee 2015).

In June 2015, Chinese Customs seized more than

100,000 t of frozen beef and other meat across 14 provinces in mainland China.

It was said someof meat was more than 40 years old and had been smuggled into Guangxi via Hong Kong.
frozen meat went through Hong Kong, then Haiphong and Mong Cai in Viet Nam.

The

The cargo was

opened in Mong Cai, commodities were transferred by locals across the border to Dongxing in
Guangxi and further to other locations in mainland China (Lau, 2015 and Lee, 2015).
Dent and Clarke (2015) found that Hong Kong has not only become less important as a re-exporterto mainland China, but also that Thailand has replaced Hong Kong as the main (re)exporter of fins,primarily exporting to Japan and Malaysia (Dent and Clarke 2015).
Customs records from mainland China and Hong Kong.

This is based on the official

However, the traders from Hong Kongare still actively organizing shark fin trade to mainland China from around the world, therefore theborder trade of mainland China with her neighbouring countries requires close examination,
especially the southern border with Viet Nam that has been used for shark fin smuggling.
Taiwan’s shark fin imports experienced two waves of increases, with the first occurring between
2005 and 2011.

A second occurred after a 50% reduction in imports during 2012, after which

imports increased again between 2012 and 2014.

A shark fin import regulation was enacted on 1stJune, 2012 in Taiwan, to only allow shark fin imports from legal sources with relevant
documentation (such as vessels registered with Regional Fisheries Management Organizations(RFMOs)).

The new regulation also prohibits the shark fin re-export from non-RFMO countries(member or co-operating non-member).

It was said the new regulation and accompanied

inspection caused the import decrease in 2012 (Dr K.K. Wu from Kaohsiung Ocean University inlitt. to Joyce Wu).

The import in 2013 and 2014 had increased gradually to the level of 2010 and2011 when importers became familiar with the new shark fin import regulation, however the main
suppliers have changed.

In 2010, Gambia was the largest supplier for Taiwan’s shark fin import,

accounting for 29% of total annual import, followed by mainland China (13%), Indonesia (12%) andTrinidad and Tobago (11%).

Mainland China (25%) became the largest source for Taiwan’s shark

61 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

fin import in 2011, followed by Suriname (14%) and Spain (14%).

Spain became the largest

supplier for Taiwan’s shark fin import in 2013 and 2014, accounting for 32% and 49%, respectively.
Mainland China only supplied 21% and 8% of shark fin for Taiwan’s annual shark fin imports in2013 and 2014, respectively.

The significantly increased supply from Spain may be because

Spanish traders were able to provide relevant documents which match with Taiwan’s shark fin
import regulation.
Taiwan shark fin exports remained relatively stable between 2005 and 2011, but after a decrease in2012, exports remained at low levels in 2013 and 2014.

Taiwan imported shark fins from 60

countries/territories, and exported to 18 countries/territories.

The significant drop in (re)exports

from Taiwan since 2012 may be as a result of the anti-corruption policy launched in mainland
China as well as the crackdown on some shark fin processors in mainland China because of tax
evasion (Dr K.K. Wu from Kaohsiung Ocean University in litt. to Joyce Wu).

It is not known how

much of the large amounts of retained shark fin have been sold in Taiwan for domestic
consumption, and if any of these were smuggled to mainland China or elsewhere.
In Taiwan since 2000 some NGOs have called for a ban on the serving of shark fin at banquets
hosted by government departments. At least some banquets have followed the call and no longer
serves shark fins. In 2013, the Fisheries Agency of Taiwan promoted the utilization of the whole
shark, including the fins, which attracted a lot of public criticism (Anon., 2013e). Despite the public
criticism of current Taiwan Government policy, the government has not restricted its policies toreflect these publicly held views. A survey in 2011 found that 71 out of surveyed 76 high-end hotels
in Taiwan offered shark fin menus for wedding banquets (Anon., 2011b).
The shark fins that Taiwan imported from Hong Kong fluctuated greatly from year to year.

Nearlyhalf of all shark fins that Taiwan imported from Hong Kong over the ten-year period were imported
in 2005 alone, and a further 34% were imported in 2011.

Taiwan’s shark fin imports frommainland China exhibited an increasing trend, with two significant periods of increase in 2011 and2013.

Taiwan’s shark fin imports from Spain increased around 67% from 2010 to 2011, andincreased again in 2013 and 2014.

This increase in Taiwan’s imports was a likely result from the

newly-launched shark fin import regulation, and somewhat offsets Hong Kong and mainland
China’s decreasing imports.
Hong Kong continues to be the largest trading hub for shark fins, supplying mainland China, whichis the largest consumer market in the world (Dent & Clarke, 2015). Taiwan has long been one of thelargest (ranking 4th worldwide) shark catchers.
other for their shark fin business.

This fact itself can tell how they are relying on eachHence mainland China is the largest consumer with Hong Kong

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 62

a hub and Taiwan a major supplier.
revealed these close links.

However, the official recorded data have not always fully

The complexities of shark fin trade routes may obscure such links, whileclandestine illegal trade adds further difficulties in understanding and managing a legal andsustainable shark fin trade.
As discussed above, Taiwan’s increase in shark fin imports from 2012 to 2014 meant a return to theoriginal level; the decreased shark fin (re)export during the same period was partly, if not all, due tothe reduced price and government crackdowns in mainland China.

It is not clear whether or how

much the observed increases of shark fin retention in recent years in Taiwan would move to thedomestic consumption.

A report in 2012 claimed that the owners of fishing vessels stockpiled

shark fins in their freezers, but were not selling those because of declining market demand anddecreasing prices (Lu 2012).

This indicates that in addition to promoting shark fin consumption

in places such as Taiwan and other Chinese ethnic markets other than Hong Kong and mainland
China, fishing vessel owners have also passively stockpiled raw shark fins.

Taiwan’s shark finexports to mainland China also fluctuated, but with an overall decreasing trend, including a morethan 70% decrease between 2009 and 2010.
In September 2015, Greenpeace found a Taiwan-flagged vessel illegally fishing in the Western
Pacific Ocean without appropriate fishing licences and violating the 5% shark fin ratio rule (Anon.,2015c).

This violated Western Central Pacific Fisheries Commission (WCPFC) requirements.

The shark fins found on the vessel included Blue Shark, Silky Shark and two CITES Appendix II
species, namely Scalloped Hammerhead and Porbeagle Shark. If the two CITES-listed shark species(Scalloped Hammerhead and Porbeagle Shark) had been exported, it would more than likely violate
the issuing of CITES Export Permits.

This incident shows that there is a risk that fins from CITES-

listed shark species are mixed with other shark species for sale domestically, and for export.

It isimportant for Taiwan, as a top-ranked shark catcher, to consider developing a traceability system toidentify and monitor CITES-listed shark species – at least from the point of harvest to the point ofexport – to avoid illegal CITES trade which could jeopardize shark conservation (Mundy and Sant,
2015).

63 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

RECOMMENDATIONS
Shark fin and mobulid ray gill plates were commonly seen and sold in physical markets in mainland
China, Hong Kong and Taiwan, and advertised in online markets in mainland China, despite theconservation concerns for these species, ongoing awareness-raising work and mainland China’s
anti-corruption policy.
Mainland China, Hong Kong and Taiwan may account for more than 90% and 70% of the global
import and (re)export, respectively, between 2005 and 2011, based on FAO import data. However,possible illegal shark fin trade could indicate that the trade decline of mainland China, Hong Kong
and Taiwan may not be as severe as the official data shows.

Large amounts of shark fins andmobulid ray gill plates in the physical and virtual markets were grouped by various price categories,
however the information on species, origin and processing locations of the products were largely
lacking or cannot be confirmed.
Hong Kong, as the largest shark fin trade hub, reported 90% of all CITES shark fins imported
between 2003 and 2013, recorded in UNEP-WCMC.

However, it is only less than 7 t in 11 year,

compared with the 85, 823 t of raw shark fin recorded by Hong Kong between 2005 and 2014.
Hong Kong has imported its shark fin from more than 100 countries/territories, on the other hand
the CITES listed species of shark fin that Hong Kong imported were all from Norway.
The report recommends a number of actions regarding trade in shark fin and mobulid ray gillplates, for the attention of stakeholders in mainland China, Hong Kong and Taiwan:
Hong Kong, as the largest shark fin trading hub, handling up to 40% of global shark fin tradefrom more than 100 countries/territories, as well as roughly 90% of imports in CITES-listed
species between 2003 and 2013, recorded in UNEP-WCMC’s CITES Trade Database.
However, large inconsistencies in the data exist between trade volume recorded by UNEPWCMC and those recorded by Hong Kong Customs and Excise Department (7 t compared to85.823 t during the 11 year period, respectively).

Hong Kong, as well as the top 20 shark fin(re)exporting countries/territories, should improve their monitoring and reporting of the
shark fin and manta ray gill plate trade to ensure it meets basic reporting requirements under
CITES.

This could include periodically examining the CITES as well as Customs data withtrade partners to identify the possible gaps.

To identify/label CITES shark fins and manta ray

gill plates separately from mixed species shipments to increase the accuracy of information
reporting and recording on the species and volume, as well as issuing appropriate CITES
documents for trade.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 64Mainland China and Taiwan should ensure that all sharks and rays harvested by and landed intheir jurisdictions are legally acquired, traded with the correct species name and withappropriate documents.

It is advised that a traceability system for CITES listed shark and ray

species could be developed and applied from harvest to the point of first export in all sharkand ray catching countries/territories.


The responsible CITES authorities in mainland China, Hong Kong and Taiwan should
enhance awareness of regulations on the shark fin and manta ray gill plate trade to otherrelevant authorities, such as Customs, quarantine and coastguard, in order to increase thedetection of illegal trade. Relevant trainings, including species and products identification,
should also be provided if necessary.



Increase awareness of regulation and product identification among the shark fin and manta
ray gill plate trading and processing industries in mainland China, Hong Kong and Taiwan, toincrease the support and compliance to CITES by the shark fin industries. Productidentification and regulation awareness training should be provided to frontline officers if
necessary.

Register all merchants on the physical and e-commerce markets that are involved in the tradeof CITES-listed shark species, and require documented evidence of legal sourcing.



Increase the knowledge of shopkeepers and e-commerce companies on the CITES regulations,e-commerce policy and legal sourcing practices of shark fins and manta ray gill plates, as wellas the importance of correctly labelling information as to the species and origin of the fins andgill plates to enable informed consumer choice.

Monitor domestic markets and e-commerce websites to verify the legality of shark fins andmobulid ray gill plates available on the market, including the use of correct labelling of species
and origin of the products.



The relevant authorities in mainland China (China CITES MA), Hong Kong (AFCD) andTaiwan (BOFT) should improve the accuracy of their record keeping and reporting of the
trade of CITES-listed sharks and mobulid rays to the CITES Secretariat.

Introduce Customs codes in mainland China and Taiwan to distinguish between raw andprocessed, as well as dried and frozen shark fins, which would help to enhance trademonitoring.

Enhance the monitoring and patrolling of trade routes such as between Hong Kong and Viet
Nam (and possibly to other countries/territories, e.g. mainland China), especially in thedetection of illegal trade in shark fin and mobulid ray gill plates, as well as to research andquantify related trade levels and to develop target strategies to combat illegal trade.

Authorities in mainland China, Hong Kong and Taiwan should co-operate, including throughregular exchange and setting up a joint task force, in order to ensure the legality of trade inshark fin and mobulid ray gill plate.

65 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan



Furthermore, the Customs and trade authorities in mainland China and Taiwan need to
examine the procedure of trade management and data recording to understand the reason for
their trade data reporting lower volumes than their trade partners.

This should help clarify

whether illegal trade is a component of the overall trade.


The relevant authorities, such as trade, commerce and fisheries, in mainland China, Hong
Kong and Taiwan should conduct regular inventories of shark fins and mobulid gill plates tounderstand the availability and consumption volume in their jurisdictions, and to verify if thevolume unreasonably exceeds the sum of imports and harvests.

Evidence-led consumer behaviour change approaches should be applied to reduce demand forshark fins and mobulid ray gill plates products in target markets.

Mainland China’s anti-corruption measures, including the ban of shark fin consumption in
official receptions, may have contributed to a decrease in consumption and consequently areduction of availability in the market. This example shows that government-led policy
interventions can contribute to decreased consumption and should be explored further.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 66

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TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 70

AnnexAnnex 1. CITES listed Shark species
SpeciesCommon NameCITES Appendix

Effective
Date

Cetorhinus maximus

Basking sharkII

13/02/2003(previously III since
13/09/00)
Rhincodon typus

Whale sharkII

13/02/2003

Carcharodon

Great white sharkII

12/01/2005(previously III sincecarcharias

13/09/00)
Pristidae spp.

SawfishesI

13/09/2007

Porbeagle sharkII

14/09/2014(7 species)
Lamna nasus(previously III since
13/09/00)
Carcharinus

Oceanic whitetip sharkII

14/09/2014

Scalloped hammerheadII

14/09/2014

longimanus
Sphyrna lewini(previously III since
13/09/00)
Sphyrna mokarranGreat hammerhead sharkII

14/09/2014

Sphyrna zygaena

Smooth hammerheadII

14/09/2014

II

14/09/2014

shark
Mobulid spp.

Mobulid rays

Source: CITES website, https://cites.org/eng/prog/shark/history.php.

71 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Annex 2. Customs codes of shark fins in mainland China, Hong Kong and Taiwan, 2005-2014
Codes

Description

Valid Year

Import tariff and
VAT

Mainland China Customs codes for shark fins
03055920

dried sharks' fins

Until 2011

03057100

shark finSince 2012

(Most-Favoured

15% for MFN

Nation)

80% for othernations

13% VAT

Hong Kong Customs codes for shark fins
03055950

dried shark fin withTill 2011

The is no import tariff

03057111

cartilage

Since 2012

or VAT (value added

03055960

dried shark fin without

Till 2011tax) for import of

03057112

cartilage

Since 2012

shark fin into Hong03056930

salted shark fin withTill 2011

Kong03057121

cartilage

Since 2012

03056940

salted shark fin without

Till 2011

03057122

cartilage

Since 2012

03057190

shark fin, NESOI

Since 2012

03038100

frozen shark

Only include data
since 2012 for thisresearchTaiwan Customs codes for shark fins
03041030005

chilled shark fin

03041930006
03028993007

Until 2008

2009/01/01 -NI, SV, HN

2013/11/29



1.8% for NZ

Since 2013/11/29



5.6% for SG

17.5% for other

0% for PA, GT,nations (include WTO
members andreciprocal relationshipnations)
03055920008
03057120002

dried shark fin

Until 2013/11/29



Since 2013/11/29

NI, SV, HN

0% for PA, GT,
1.8% for NZ

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 72



5.6% for SG

7% for WTO

members andreciprocal relationshipnations

9% for othernations
03049030008

frozen shark fin

03049930009
03038993006

Until 2008

2009/01/01 -NI, SV, HN

2013/11/29



1.8% for NZ

Since 2013/11/29



5.6% for SG

17.5% for other

0% for PA, GT,nations (include WTO
members andreciprocal relationshipnations).
03056920006

salted shark fin

03057130000

Until 2013/11/29



Since 2013/11/29

NI, SV, HN, SG

0% for PA, GT,

2.3% for NZ



9% for WTO

members andreciprocal relationshipnations

10% for othernations
03057110004

smoked shark fin

Since 2013/11/29



0% for PA, GT,

SV, HN, SG, NZ


3% for NI



30% for WTO

members andreciprocal relationshipnations

40% for othernationsNESOI: not elsewhere specified or indicatedNote: GT: Guatemala, HN: Honduras, NI: Nicaragua, NZ: New Zealand, PA: Panama, SG:Singapore, SV: El Salvador,

73 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Annex 3a. The Customs recorded shark fins import and (re)export of mainland China, Hong
Kong and Taiwan (kg).
2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

Mainland China recorded Customs data
Import3,338,41 2,662,0 2,541,78 2,004,8863(Re)expo 1,349,03
rt

2

9

89

730,740 121,969 159,415 108,692 39,433 19,637

381,468 409,334 347,010 288,763 204,184 348,721 252,395 284,093 278,137

Hong Kong recorded Customs data
Import10,348,1 9,362,4 10,183,3 9,949,5 9,358,8 9,852,6 10,292,4 3,319,9 2,659,5 2,711,3
42

86

81

56

25

09

21

64

(Re)expo 7,134,41 5,958,6 5,669,59 5,293,3 4,919,3 5,041,3 3,353,75
rt

7

10

0

75

70

58

1

867,71922

47

1,196,9 1,189,7
89

33

Taiwan recorded Custom data
Import433,651 710,684 566,295 791,893 987,847(Re)expo 1,141,35
rt

7

974,745 902,838 846,161 913,806

1,166,4 1,268,29
72

1

1,057,7
42633,065 978,772

1,195,0
58

953,536 356,684 166,183 260,150

Source: Customs records from mainland China, Hong Kong and Taiwan.
Annex 3b. FAO recorded shark fins import and (re)export of mainland China, Hong Kong andTaiwan (t), 2005-2011
2005

2006

2007

2008

2009

2010

2011

FAO recorded mainland China shark fins import and (re)export
ImportExport

3,338

2,662

2,542

2,005

731

147

159

(22%)

(19%)

(18%)

(15%)

(6%)

(1%)

(1%)

1,349

381

409

347

289

204

343

(11%)

(4%)

(4%)

(4%)

(3%)

(2%)

(5%)

FAO recorded Hong Kong shark fins import and (re)export
Import(re)export

10,348

9,363

10,183

9,950

9,358

9,852

10,293

(67%)

(67%)

(71%)

(72%)

(79%)

(82%)

(81%)

7,134

5,962

5,670

5,294

4,919

5,043

3,354

(57%)

(60%)

(60%)

(58%)

(56%)

(51%)

(45%)

FAO recorded Taiwan shark fins import and (re)export
Import

434

708

564

792

988

1,156

1,260

(3%)

(5%)

(4%)

(6%)

(8%)

(10%)

(10%)

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 74

(re)export

1,141

974

903

846

913

1,051

954

(9%)

(10%)

(9%)

(9%)

(10%)

(11%)

(13%)

FAO recorded global shark fins import and (re)export
Import15,37014,046

14,32013,781

11,88012,031

12,654(re)export

12,458

9,862

9,513

9,083

8,738

9,941

7,393

Source: FishstatJ, 2015.
Note: China’s record did not separate the export from re-export.
Most of (re)export from Hong Kong were actually re-export.
Most of (re)export from Taiwan were actually export.
Annex 4. The shark fin import and (re)export (t), mainland China, Hong Kong, Taiwan andestimated world trade 2005-2011
2005

2006

2007

2008

2009

2010

2011

Mainland China shark fins import and (re)export
Import(re)export

3,416

2,662

2,546

2,019

732

182

161

(20%)

(16%)

(15%)

(13%)

(5%)

(1%)

(1%)

1,398

571

552

394

382

314

489

(11%)

(5%)

(2%)

(3%)

(3%)

(2%)

(3%)

Hong Kong shark fins import and (re)export
Import(re)export

10,3959,365

10,192

9,950

9,356

9,873

10,293

(59%)

(58%)

(60%)

(66%)

(70%)

(73%)

(74%)

7,132

5,963

5,670

5,300

4,875

5,043

3,354

(54%)

(55%)

(24%)

(38%)

(36%)

(30%)

22(%)

Taiwan shark fins import and (re)export
Import(re)export

434

711

573

796

978

1,157

1,260

(2%)

(4%)

(3%)

(5%)

(7%)

(9%)

(9%)

1,241

1,048

1,015

916

975

1,145

1,065

(9%)

(10%)

(4%)

(7%)

(7%)

(7%)

(7%)

Estimated World shark fins import and (re)export
Import17,492

16,27016,877

15,177

13,327

13,53814,004(re)export

13,124

10,844

23,408

13,958

13,69016,98015,077

Source: Dent & Clarke (2015)

75 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Annex 5. Seven e-commerce websites monitored for shark fins and mobulid ray gill plates inmainland China, 2015
Websites

Language

Target markets#1

Chinese

B2B, Domestic market and Chinese speakers
around the world#2

Chinese

B2B, Domestic market and Chinese speakers
around the world#3

Chinese

B2B, Domestic market and Chinese speakers
around the world#4

EnglishB2B, global market#5

Chinese

B2C, Domestic market and Chinese speakers
around the world#6

Chinese

B2C, Domestic market and Chinese speakers
around the world#7

Chinese

C2C, Domestic market and Chinese
speakers around the world

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 76

Annex 6. Shark fin import and (re)export between mainland China, Hong Kong and Taiwan.

Source: Customs data for mainland China, Hong Kong and Taiwan, 2005-2014.
Note: Hong Kong changed some of its shark product codes in 2012, including the re-classification of wet
shark fins as frozen shark meat.

To get around this for purpose of analysis, the frozen shark meatcode had to be adjusted for the years 2012 to 2014 in order to capture the proportion that is salted(frozen) shark fin with cartilage.

77 TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan

Annex 7. Mainland China shark fin import adjusted with Hong Kong’s (re)export to mainland
China (t).
20

20

20

20

20

20

20

20

20

20

Tot

05

06

07

08

09

10

11

12

13

14

al

3,3

2,6

2,5

2,0

73

12

15

10

39

20

11,

38

62

42

05

1

2

9

9

adjust with Hong Kong

9,4

7,6

7,2

6,2

3,7

1,1

1,3

1,2

14

(re)export to mainland China

14

10

52

90

27

46

63

30

2

original mainland China import

727
96

38,
270

Source: Customs data of mainland China and Hong Kong, 2005-2014.

TRAFFIC report: Shark Fin and Mobulid Ray Gill Plate Trade in mainland China, Hong Kong and Taiwan 78

JUNE 2016

TRAFFIC, the wildlife trade monitoring network,is the leading non-governmental organization
working globally on trade in wild animals andplants in the context of both biodiversity
conservation and sustainable development.
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TRAFFIC
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