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Jurisdictions Surveyed: Angola | Argentina | Botswana | Bulgaria | Cambodia | China | Democratic Republic of the Congo | Côte d’Ivoire | Egypt | Gabon | Georgia | Ghana | Greenland | Guyana | India | Indonesia | Kazakhstan | Liberia | Nepal | Pakistan | Russia | Thailand | Turkey | Vietnam
Appendix: Mexico | Saudi Arabia | United Arab Emirates | United Kingdom

Cambodia

Cambodia has wild animal wet markets. A 2003 sub-decree on food hygiene regulates food market sanitation. Cambodian wild animals are deemed to be state property. Trading in endangered animals is restricted, and trading in common wild animals is regulated.

I. Overview

Cambodia has wild animal wet markets.[1] Consumption of wildlife meat is a Cambodian holiday practice and serving such meat may be a status symbol in urban areas.[2] The country is also a transit point for the trafficking of wild animals to Vietnam and China.[3] There is a sub-decree regulating markets and other establishments that deal with food. Food hygiene regulations also contain provisions applicable to food derived from animals. The wild animal trade is prohibited by law, except for persons holding permits to trade in common wildlife species.[4]

II. Food Sanitation Regulations

Under the 1990 Sub-Decree No.02 AN.Kr on Food Hygiene, “food  production  bases,  stock  and  distribution places,  [and] restaurants  shall  have suitable installations with hygienic characters.”[5] Food hygiene officials of the Health Ministry, or those appointed by provincial or municipal people’s committees, may inspect food, including animal meats.[6]

The 2003 Sub-Decree No. 47 on Food Hygiene for Human defines “food” as “the substances[,] whether they are fully or half or not yet processed[,] which are intended to be used as food for people.”[7] The Sub-Decree states as follows:

Article 45
Food products shall be effectively protected from heat, sunlight, dirt, changes of weather, insects, rodents and other animals. Food products which may go spoilt easily shall be stored in a proper cool condition by using ice or other means. Tools and other kinds of materials used for producing food products shall be kept in a clean condition and shall be sterilized if necessary.

Article 46
Bodies and clothes of the staff members whose duty is to mix, handle and touch food products shall be hygienically clean. Those staff members shall not have skin diseases and other infectious diseases which may contaminate food.

Article 47
At permanent market places, washing instruments shall be readily prepared for people who mix, handle or touch food products to wash their hands in a hygienic manner if there are no permanent hygienic instruments. There shall be a clean water place for washing and cleaning instruments and equipment.

Article 48
At permanent market places, there shall be a suitable place or/and suitable containers for storing substances and hazardous wastes and/or uneatable products whether solid or liquid before discharging them to the ultimate places as defined by the competent authorities.

As a general rule for food handling, food products must be protected from all sorts of contamination by adequate wrapping, except those food products that have their own natural protections such as peel, scale, or skin that needs to be first removed before eating. Sellers must prohibit their customers from handling or touching their food products with bare hands, except the kinds of food with natural protections or that are properly wrapped.[8] When preparing food, wastes must be frequently discharged from the working places. Those wastes must be quickly dumped into garbage cans with lids which tightly close between each use and be discharged, washed, and disinfected at least once a day.[9] Places dealing with food must have an adequate supply of drinkable water. Drinkable water must be used to treat food.[10]

In addition, Sub-Decree No. 47 requires that any surface that directly touches food must be smooth and durable enough to withstand repeated washing and sterilization. Wooden tables and chopping boards used for cutting meat must be carefully cleaned and sterilized after the completion of each workday.[11] Food products ready for sale must be kept or displayed for sale in a way that prevents spoiling or contamination. Stalls for selling goods, and tables for selling meat, fish, vegetables, and fruits, must be made from washable materials and kept in clean condition with regular maintenance and sterilization. Food products must not be displayed at a place that is lower than 50 cm (about 20 inches) from the ground.[12]

III. Wild Animal Protection

Cambodian animals are state property under the Forestry Law of 2002. The Law states “[a]ll kinds of wildlife species in the Kingdom of Cambodia are State property and the component  of  forest  resources, including  all  species  of  mammals,  birds,  reptiles,  amphibians, insects, other invertebrates, and their eggs or offspring.”[13] 

All wildlife is classified in three categories: endangered species, rare species, and common species. The 2002 Law requires that

[the] Ministry of Agriculture, Forestry and Fisheries, through the proposal of the Forestry Administration, shall issue a Prakas [regulation] to determine the criteria for each category and establish a separate list for endangered and rare species, which may vary between regions in Cambodia, with consultation with [the] Ministry of Environment.[14]

The Law prohibits hunting, harming, or harassing all wildlife by using any type of dangerous means, hunting during the prohibited season, and hunting in protected zones and special public areas.[15] In addition, the Law prohibits anyone from transporting and trading in rare and endangered wildlife species. The Law also prohibits anyone from transporting and trading in common wildlife species in an amount exceeding that necessary for customary (subsistence) use without a permit issued by the Forestry Administration.[16]

Trading in endangered wildlife species is punishable by imprisonment for five to 10 years.[17] Trading in rare species is punishable by imprisonment for one to five years, a fine of 10 million to 100 million Riels (US$2,400 to US$24,000), or both.[18] Trading in common species of wild animals in breach of the Law is punishable by a fine equaling two to three times the market value of the animal.[19]

In addition, under the Law on Nature Protection Area, the catching, trapping, poaching, poisoning, and collecting the eggs or offspring of wildlife is an offense punishable by fines from 100,000 Riels (US$24) to one million Riels (US$240) on top of restoration damages.[20]

IV. Law on Animal Health and Animal Production

The Law on Animal Health and Production[21] contains the following chapters that may be relevant to processing and trading in wild meat: Slaughterhouse and Sanitation (Chapters 8), Movement of Animals and Animal Products (Chapter 9), Animal Welfare (Chapter 11), and Inspection (Chapter 19).[22] An English translation of the Law was not located.                      

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Prepared by Sayuri Umeda
Senior Foreign Law Specialist
August 2020


*At present there are no Law Library of Congress research staff members versed in Khmer. This report has been prepared by the author’s reliance on practiced legal research methods and on the basis of relevant legal resources, chiefly in English, currently available in the Law Library and online.

[1] Paula Froelich, Inside the Horrific, Inhumane Animal Markets Behind Pandemics Like Coronavirus, N.Y. Post (Jan. 25, 2020), https://perma.cc/UQ44-YMAN.

[2] Andrew Haffner, The Bushmeat Trade, Southeast Asia Globe (Apr. 14, 2020), https://perma.cc/X6W5-4YVS.

[3] Calls for an End to Cambodia’s Wildlife Trade in Response to the Coronavirus, Wildlife Alliance (Jan. 30, 2020), https://perma.cc/ADQ8-774D.

[4] Law on Forestry, NS/RKM/0802/016, Aug. 31, 2002, art. 48, https://perma.cc/25GH-AHZ5.

[5] Sub-Decree No.02 AN.Kr on Food Hygiene (Jan. 1, 1990), art. 3, https://perma.cc/SGD4-H4UU.

[6] Id. arts 7 & 8.

[7] Sub-Decree No. 47 on Food Hygiene for Human (May 16, 2003), art. 3, https://perma.cc/8C26-6NQ9.

[8] Id. art. 37.

[9] Id. art. 26.

[10] Id. art. 28.

[11] Id. art. 22.

[12] Id. art. 39.

[13] Id.

[14] Id. art. 48. Prakas 020 PRK.MAFF (2007), and Prakas 240 PRK.MAFF (2018) define the status of Cambodian animal species. Olly Griffin, The Bio Diversity of Keo Seima Wildlife Sanctuary 11 (Oct. 2019), https://perma.cc/P4VE-F52L. Texts of the Prakas were not located.

[15] Law on Forestry art. 49.

[16] Id. art. 50.

[17] Id. art. 97.

[18] Id. art. 98.

[19] Id. art. 96.

[20] Law on Nature Protection Area, No NS/RKM//0208/007, Feb. 15, 2008, art. 58, https://perma.cc/86HU-2BXA.   

[21] Law on Animal Health and Animal Production No. NS/RKM/0116/003 (Jan. 28, 2016), https://perma.cc/X93T-JJ4Q.

[22] Animal Rescue Cambodia, Dog Meat Trade Cambodia 2019: Key Findings of Investigations in Siem Reap 12 (2019), https://perma.cc/9QG6-FMGL.

Last Updated: 12/31/2020