Of the three most illegally trafficked animals in the world, most Americans can probably guess two. Elephants and rhinoceroses have long been targets of poachers. The third member of the unfortunate trio is an unassuming mammal that has historically received less attention in the U.S. — the pangolin. These three species comprise almost 75% of the suspected illegal animal trafficking market.
Extinction is often a danger for a heavily trafficked creature, and the pangolin is no exception. Prized by practitioners of traditional Chinese medicine for their scales and considered a delicacy as well, their numbers have dropped to dangerously low levels. With one species already receiving protection, the U.S. Fish and Wildlife Service (FWS) proposed a rule on June 17, 2025, to list seven other species of pangolin as endangered species entitled to the protections provided by the Endangered Species Act of 1973 (ESA).
This step is one of many involved in the legal process of classifying a species as endangered. With the Trump administration threatening to weaken the ESA to make it easier to drill and develop in protected lands, the existence of the pangolin may well hang in the balance.
Isn't That a Toenail?
Topping out at around three feet long, pangolins are sometimes referred to as a "scaly anteater." Solitary and nocturnal, they survive on a diet of ants, termites, and other insects. Like an anteater, they have a long, sticky tongue for snaring their prey. Lacking teeth, they ingest stones for their gizzard, which grinds up their food for digestion.
While they have sharp claws for burrowing into trees and insect mounds, pangolins are built for defense. They're covered with sharp scales made from keratin, the same substance found in human fingernails and toenails. They can also expel a noxious chemical, much like a skunk. When threatened, their usual reaction is to curl into a ball and let predators decide if braving their armor is worth it.
Unfortunately, poachers have ways to circumvent the pangolin's defensive measures. The scales are reputed to have healing properties by practitioners of traditional Chinese medicine, although research has yet to prove that dubious claim. As they are also considered a delicacy in Southeast Asia and other locales, they remain in high demand despite international protections such as CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora).
Staving Off Extinction
The FWS is proposing that seven species of pangolin receive the protections granted by the ESA by being added to the endangered species list: the black-bellied pangolin, the Chinese pangolin, the giant pangolin, the Indian pangolin, the Philippine pangolin, the Sunda pangolin, and the white-bellied pangolin. It also intends to revise the entry for the Temmick's ground pangolin, which has been protected for decades.
While literally anyone can submit a request to the FWS or the National Oceanic and Atmospheric Administration (NOAA) for a species to be considered for endangered or threatened status, it's just the first step in a lengthy legal and administrative process.
When a petition is received, the FWA has 90 days to review the submission and determine if it's worthy of consideration. If it is, a year-long review begins. The agency in charge examines all submitted commercial and scientific information, which can either support or refute the request.
If you're wondering who would object to an endangered species getting protections, it's important to note that economic factors are explicitly not part of the consideration process. Whether a multi-billion-dollar drilling or construction project would be halted by ESA-protection approval isn't a determining factor. Therefore, most opposition comes from those with financial issues at stake.
The ESA requires that at least one of the five following factors apply for an animal to be considered for listing:
- Disease or predation
- Failure of other regulations or measures to protect a species
- Loss of a species’ habitat or range
- Over-exploitation of a species
- Other natural or manmade factors that threaten the species
The pangolin checks the boxes on all of these, so it wasn't surprising that the FWA issued its proposed rule.
The next step is a period of public comments and hearings, with submission deadlines of 60 and 45 days, respectively. After this information is received, the process continues for another year before a final rule can be issued. If approved, the species in question receives an official listing as either threatened or endangered and all of the protections provided by the ESA.
Why does it take so long for a critter like the pangolin to be protected by the ESA? Like all government agencies, the FWA is required to follow the Administrative Procedure Act rulemaking process when considering such actions. ESA protection wasn't enough to save creatures like the Little Mariana fruit bat or Bachman's warbler. Hopefully, it arrives in time to keep pangolins from vanishing as well.
Related Resources
Animal Rights and Pet Laws (FindLaw's Learn About the Law)
The Endangered Species Act of 1973 (FindLaw's Litigation and Disputes)
Conversationalists Sue To Protect Chinook Salmon Populations (FindLaw's Courtside)
