Chapter Two: Individual Hospitals and Doctors

i. Volume of Evidence

The primary focus of this update is transplant volumes.  Before getting into that, we need to address the volume of evidence about the killing of prisoners of conscience, primarily Falun Gong, for their organs.

Many claims of human rights abuses suffer from having too little evidence. With this claim of transplant abuse in China, the volume problem is the opposite – too much evidence.

There are now three books on the issue, our two and State Organs, a collection of essays which David Matas edited with Torsten Trey, published in 2012. There is an NGO dedicated to combating the abuse – Doctors Against Forced Organ Harvesting (DAFOH). There is a website focused on the issue alone – There have been five documentaries produced on the violation – Transmission 6‑10, Free China, Red Reign, Human Harvest, and Hard to Believe. About the killing of Falun Gong for their organs, there is more than just a collection of evidence; there is a field of knowledge.

In a world of thirty‑second soundbites and 140‑character messages, the volume of evidence is a problem. The gravity of the abuse would be a lot easier to communicate if less information were needed to show that it is happening. The number of people who have the patience to wade through all the information available on the killing of Falun Gong for their organs to come to their own conclusion is, unfortunately, comparatively small.

One reason that the abuse has not received the global attention it deserves is the sheer volume of evidence that needs to be marshalled to show that the abuse exists. If we had one smoking gun or, as David Kilgour has put it, one smoking scalpel, which we could brandish to show that the abuse exists, our efforts to combat the abuse would be comparatively easy. When we have volumes of evidence that have to be considered as a whole to conclude that the abuse exists, then our audience for the abuse is regrettably but also necessarily diminished.

It may seem counterintuitive in this context to add to this problem by presenting for consideration yet more evidence. What this update addresses is not more of the same – more data in fields already explored. Rather, it explores a whole new data field – the data from individual hospitals.  We had in the past looked at particular hospitals to point out that their websites were promoting transplant tourism. Here, we look to them for transplant volumes.

Reliable transplant volume aggregates in China do not exist. The Chinese health system runs four transplant registries, one each for liver, kidney, heart and lung. Public access to the aggregate data for these four registries, which does not now exist, would be useful, if for no other reason than to cross check the proliferation of contradictory statements Chinese officials make about transplant volumes. Yet, any registry is only as reliable as the reports it receives.  These registries accumulate their data from reporting hospitals.  We cannot assume that every hospital reports all of its transplants to these four registries.

Considering transplant volumes, hospital by hospital, doctor by doctor is, in China, a mammoth task. There are almost nine hundred hospitals and between nine and ten thousand medical personnel engaged in transplants.  Moreover, cover up is not just in China an aggregate, national phenomenon. It exists as well at the doctor and hospital level. Nonetheless, to get a grip on transplant volume figures, it is a task which must be undertaken and we do so in this update.

We do this not just to attempt to make more convincing the point we have made before.  If you have gone through everything we have written up to now and are not already convinced that innocents in China are being killed for their organs, more data will not convince you.  We make the additional effort to make an additional point – that the number of innocents killed for their organs in China is far larger than we had contemplated.  The numbers stagger the imagination.

ii. Features

When we look at hospitals and doctors one by one, a number of features jump out. One is the sheer volume of transplants.

The total number of transplants which officials ascribe to the country as a whole, ten thousand a year, is easily surpassed by just a few hospitals. Whatever the total number is, it must be substantially more, by a multiple, than the official figure.

Second, many of the hospitals are relatively new or have new transplant wings or beds. This development would not have occurred without confidence in a continuing supply of organs for transplants. The transplant business in China has developed with not only an abundance of available organs from 2001 on, but also with a confidence that this abundance would continue into the indefinite future.

Third, concomitant with the large number of transplants, there is a large number of qualified staff.  The transplant industry in China employs a lot of people. The investment in people as well as buildings is another testimonial to the ready availability of high volumes of organs available for transplants, not only in the immediate past and present, but also, in the view of those who have committed their careers and the careers of others to this profession, into the indefinite future.

Fourth, the transplant professionals in China are engaged in substantial training and research.  Research and training in transplants cannot be done without transplants. The high volume of research bespeaks itself a high volume of transplants and a ready availability of organs for transplants.

Fifth, the combination of a large professional corps, a substantial building stock and significant research speaks money.  Transplantation in China means money, lots of it.

iii. Numbers & Classifications of Organ Transplant Centers

According to statistics from the Administration of Hospitals under the National Health and Family Planning Commission (NHFPC) in July 2015,2 there were 20,918 hospitals in mainland China. 3 Among them were 1,151 Class 3 hospitals and 4,321 Class 2 hospitals. 4

Class 3 hospitals are normally located in major cities. They are typically large-scale general or specialized hospitals with over 500 beds. Among them, 705 are Class 3 Grade A (“3A”) hospitals. 5

Huang Jiefu, former Deputy Minister of Health, said in March 2006, “For a hospital to pass the evaluation to become a class 3A hospital, it must have completed a fixed target of more than five organ transplants. Organ transplantation has become a resource for competition among hospitals to reach the standard and for their branding,” “At present, the country has too many, not too few, hospitals carrying out kidney, liver, heart, and other types of transplants.”6

The World Organization to Investigate the Persecution of Falun Gong completed a comprehensive investigation of both organ transplant hospitals and doctors and determined that 865 hospitals are involved in organ transplantation. The hospitals are to be found in 22 provinces, five autonomous regions, four centrally-administered municipalities, and 217 prefecture-level cities. 7

Diagram 2.1 Geographic distribution of the 865 medical institutions involved in organ transplantation


We have verified and confirmed 712 hospitals which carry out liver and kidney transplants. The qualifications and composition of the 712 liver and kidney transplant hospitals are:

Table 2.1 Distribution of 712 liver and kidney transplant hospitals:

(A)(A) / Total (712)(B)(A)/(B)
Hospital ClassificationNumber of Hospitals InvestigatedPercentage of 712 Hospitals Conduct Liver and Kidney Transplants InvestigatedTotal Hospitals In ClassificationPercentage of Total Hospitals In Classification
Class 3 Grade A55177.4%70578.2%
Class 3 Grade B547.6%19827.3%
Class 3 Grade C10.1%1860.5%
Class 3 Other620.0%
Class 3 Total60685.1%1,15152.6%
Class 2 Grade A9613.5%2,0734.6%
Class 2 Grade B40.6%7540.5%
Class 2 Grade C490.0%
Class 2 Other1,4450.0%
Class 2 Total10014.0%4,3212.3%
Class 1 Grade A20.3%
Class 1 Other40.6%


In fact more than 1,000 hospitals in China applied for permits from the Ministry of Health in 2007 to conduct transplants, implying that they had met the Ministry’s minimum transplant bed count requirements.8 In April 2015, Professor Ye Qifa from Central Medical University, Executive Chairman of the China Organ Transplant Alliance, who specializes in major organ transplantation, stated to a People’s Daily Online correspondent that, before the introduction of the “Human Organ Transplant Ordinance” in 2007, there were over 1,000 medical institutions in China performing organ transplants.9

The Ministry of Health on May 23, 2007 announced a list of 87 transplant hospitals10 approved by the Review Expert Team of the Human Organ Transplantation Skills Clinical Application Committee, authorized by the Ministry of Health, to which we refer as “national level” hospitals. Essentially, these were the most qualified and capable national-level organ transplant centres at the time. At the same time, it announced a second list of hospitals designated to perform organ transplants, issuing 18-month temporary permits to 77 transplant centres with weaker qualifications, to which we refer as “regional level” hospitals. In total, 164 hospitals were given permits to conduct organ transplants.11

On August 8, 2013, the National Health and Family Planning Commission (successor to the Ministry of Health) published a list of 165 hospitals approved to conduct organ transplants,12 including Wuhan University Zhongnan Hospital Human Organ Transplant Centre, which performs transplants from bodies with no cardiac activity. Four more hospitals were added to the list by the beginning of 2014, bringing the number of qualified hospitals to 169.13

This report focuses on the 164 hospitals which received approval from the Ministry of Health in 2007, so that we can categorize their qualifications as either national or regional level. If we exclude the 18 heart and lung transplant centres, 146 transplant centres remain. These include 23 national-level military and armed police hospitals that were among the first batch approved in 2007, 58 national-level civilian hospitals, and 65 designated hospitals.

Among the 566 kidney and/or liver transplant centres which did not receive approval from the Ministry of Health, 405 were based in large-scale 3A hospitals. These included 56 military and armed police organ transplant centres, 349 mostly-3A civilian hospitals, and 161 medium-sized hospitals (including 55 Class 3 Grade C hospitals and 106 mostly-Class 2 hospitals).

Table 2.2 Classification of 712 hospitals conducting liver/ kidney transplants:

Type of Transplant CentreCount
National-level military and civilian liver and kidney transplant centres approved by the Ministry of Health in 200778
Liver and kidney transplant centres designated by the Ministry of Health in 200768
Unapproved large-scale (mainly 3A) transplant centres405
Unapproved medium-size (mainly Class 3C and Class 2) transplant centres161
Total liver and kidney transplant centres investigated712


In the next section, we set out examples of different types of transplant centres, showing their qualifications, characteristics, transplant volume and capacity, and rates of growth. These examples give us an indication of overall transplant volume.


2 Home Page of Chinese Hospitals Directory

3 There are 20918 hospitals in China in 2010  Xinhua net 2011-08-17
2010年全国共有各级各类医院20918家     2011年08月17日 来源: 新华网

4 Chinese Hospital Class Inquiry System

5 Chinese Hospital Class Inquiry System

6 The Difficulty of Legislation in Organ Transplantation
Source: Life Week , 2006 Issue 13 / April 17, 2006;  Author: Guo Na
《三联生活周刊》器官移植立法之难 2006-04-17  作者:郭娜  2006年第13期

7 WOIPFG Releases List of 7371 Medical Personnel from 765 Non-Military Medical Institutions Suspected of Harvesting Organs from Living Falun Gong Practitioners
WOIPFG Releases List of 2098 Medical Personnel in 100 People’s Libertion Armyand Armed Police Hospitals Suspected of Live Organ Harvesting of Falun Gong Practitioners

8 Climbing the peak of transplantation, continue the wonderfulness of life
攀登移植之巅 延续生命精彩

9 Wuhan University Research Institute of Hepatobiliary Diseases: A Race against Time – Hubei Channel   May 21, 2015   Zhang Pei
武大肝胆疾病研究院:器官移植与时间赛跑   [日期:2015-05-21]  来源:人民网-湖北频道  作者:张沛

10 Notice from Office of the Ministry of Health on Registration of Medical Departments for Human Organ Transplantation
National Health and Family Planning Commission of the People’s Republic of China   NHFPC Publication [2007] No. 87

11 164 hospitals in China passed examination and approval by the Ministry of Health to carry out organ transplants
Source:  China News Net    August 18, 2007
Original link no longer accessible. Refer to archived link:

12 List of Hospitals Approved to Carry Out Human Organ Transplantation National Health and Family Planning
Commission of the People’s Republic of China
已批准开展人体器官移植项目的医院名单 , 中华人民共和国国家卫生和计划生育委员会, 2013-08

13 List of Hospitals Approved to Carry Out Human Organ Transplantation
National Health and Family Planning Commission of the People’s Republic of China
《已批准开展人体器官移植项目的医院名单》, 中华人民共和国国家卫生和计划生育委员会, 2014-01-07