November 2020

Gill plates removed from mobula rays in Sri Lankan fish market.

At the end of last month, Hong Kong customs authorities seized one of the largest consignments of gill plates to date. The shipment arrived in Hong Kong from Sri Lanka and contained 330kg of dried manta ray gill plates with an estimated value of $116,000 USD.

If you have not had a chance to read the press release you can find it here. In a nut shell though, this haul was legally fished in Sri Lanka as although Sri Lanka are party to the Convention on the Conservation of Migratory Species of Wild Animals (CMS), they haven’t established legislative framework to implement the CMS convention and protect manta rays. The reason this haul was stopped was that no valid CITES permit was provided on inspection in Hong Kong. It turns out the required permit for export from Sri Lanka was issued but the original paper document was not provided to Hong Kong Customs on request. Once a physical copy of the CITES permit is submitted to Hong Kong Customs, and if the quantities match the permit, the consignment will no longer be illegal and will be released.

Since we released a press release about this story, I spoke to Stan Shea from BLOOM Association based in Hong Kong to dig deeper into this story from the perspective of a researcher and conservation advocate on the ground.

The gill plate market in Hong Kong and China

BLOOM Association conducted the most recent and complete ‘Rapid Survey of the Mobula Gill Plate Trade and Retail Patterns in Hong Kong and Guangzhou Markets’ in 2016. Much of the following information has been obtained from this rapid assessment which you can access here.

Hong Kong is one of the main markets for the sale of mobula gill plates along with Guangzhou just over the border in China. In both cases, dried manta and devil ray gill plates are sold as part of a relatively new market of Traditional Chinese Medicine (TCM). The gill plates are prepared as a tonic in the form of a soup called peng yu sai and marketed for their pseudo-medicinal properties. Gill plate medicinal claims vary from retailer to retailer and between countries/territories but include healing abscesses, measles, coughs, fever, chicken pox, and even cancer. There is currently no proven scientific backing for these claims.

Sheung Wan is a district of Hong Kong with as many as 350 dried seafood stores and is the heart of the dried seafood market in Hong Kong. Nearly 30% of these stores were found to sell mobula gill plates. Of these, less than half of the dried seafood stores had their whole gill plate stock on display and a third of stores reported selling gill plates but kept them completely out of sight. This is partly due to the relatively small store front size which limits how much stock retailers can display. Large amounts of gill plates stored out of sight make it increasingly difficult to quantify the retail market.

Manta and devil ray gill plates in the Sheung Wan stores sell for between USD$540 and USD$860 per kilogram for dried gill. Whilst in Sri Lanka I witness an oceanic manta being landed in the east of the country and meat of this 400kg animal sold for a total of USD$180 ($0.44/kg). These numbers go to show how the gill plate trade provides much of the economic incentive for fishermen to land manta and devil rays.

During the rapid assessment, each of the vendors was asked if they knew about the origin of the gill plates they were selling. A third of gill plate selling stores in Sheung Wan provided valid responses to the origin of the gills and although 14 origins were reported, Sri Lanka was not mentioned (India was). Sri Lanka was however mentioned by retailers in Guangzhou, China as an origin for mobula gill plates.

Mobula gill plates on sale in TCM market.

What does this latest seizure tell us?

This was the first public announcement from the Hong Kong Customs about a seizure of mobula gill plates as far as Bloom Association and the Manta Trust are aware. There have been plenty of similar public announcements about shark fin, totoaba fish, and sea cucumber seizures in the past but not mobula gill plates. Hong Kong Customs is under no obligation to publicly report or make announcements about such seizures, so Stan and his team are currently in contact with Hong Kong Customs to determine if there have been similar unreported seizures in the past.

Mobula gill plates ready for export from Sri Lanka.

If this is first instance (publicly announced or not), that could demonstrate a progressive shift towards clamping down on the mobula gill plate trade. In the past this has been hard to do as the trade some mobula species was not restricted and differentiating between the dried gill plates of different mobula species is particularly challenging. However, since 2017 all mobula species have been listed on the CITES Appendix II removing the need for customs officials to identify the gill plates to species level.

The original press release from Hong Kong Customs only mentioned manta gill plates. However, from photos Stan has seen of the haul, it appears the consignment was a mix of both manta and devil ray gill plates. This is to be expected as fishery surveys by Blue Resources Trust in Sri Lanka record far more devil ray landings that manta rays.

Another interesting point about this consignment was the way it arrived. As gill plates are dried, there is no urgency to transport the consignment. In the similar case of shark fins, according to Stan, most of the dried seafood consignments arrive via cargo ship to avoid the higher fees involved in air freight. It was therefore a little bit surprising to Stan that this consignment arrived by plane. Is this normal for gill plates arriving from Sri Lanka? Why have they chosen this method? Perhaps there are not as convenient shipping options along this route? Very few vendors noted Sri Lanka as the origin of the gill plates so potentially this was an unusual route.

Where does Hong Kong need to go from here?

The interception and announcement of this consignment is a positive step in the right direction and shows Hong Kong’s desire to intercept the illegal international trade of vulnerable manta and devil ray species.

In Hong Kong, species listed on the CITES Appendices are regulated by the Endangered Species Ordinance which grants permission to intercept and prosecute contraventions to this ordinance. However, wildlife trade crimes are not included in the Organised and Serious Crime Ordinance which grants great powers to future investigate the trade. As a result, fines and sentences are handed out to the traffickers caught red handed but more thorough investigations by authorities into the finances, trade routes and parties involved in the illegal trade do not happen. To better tackle the illegal trade of wildlife of manta gill plates but also rhino horns, shark fins, pangolin scales and many others, BLOOM Association believe it is important to have the Endangered Species Ordinance fall under the Organised and Serious Crime Ordinance to grant greater powers to investigate.

The Manta Trust has helped to create a field guide for mobula gill plate identification for law enforcement and trade monitoring applications and have run some training workshops on gill plates around the world. The fact that Hong Kong Customs identified these items as gill plates is a promising sign that these resources are being utilised well, it would however always be beneficial to expand these training sessions.

Mobula gill plate identification workshop supported by the Manta Trust.

Stan and BLOOM Association are eager to revisit this rapid assessment and conduct a follow up survey to see if there has been any change in the prevalence and scale of the mobula gill plate trade in Hong Kong since the listing of all mobulids under CITES and CMS conventions.