Investigation Maps CCP Control Across China's Organ Transplant System

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Investigation Maps CCP Control Across China's Organ Transplant System

19 Transplant Leaders Across 18 Hospitals

Nineteen transplant surgeons or centre directors at 18 Chinese hospitals held Chinese Communist Party membership during the period from 2020 to 2025, according to an investigation by China researcher Sarah Cook. Six also served as hospital Party secretaries or deputy secretaries, combining medical responsibilities with senior political authority.

Contents
  1. 19 Transplant Leaders Across 18 Hospitals
  2. Who Has the Final Say Inside Hospitals?
  3. National Oversight Follows the Same Hierarchy
  4. How Organ Recovery Is Organised
  5. What Happens When a Doctor Speaks Up?
  6. Why Xinjiang and Falun Gong Feature in the Findings
  7. From the 2015 Reform Claim to the Tribunal's Findings
  8. International Cooperation Is Expanding
  9. What the Investigation Recommends
  10. Key Points

The cases span 12 provinces or municipalities. They form part of Chinese Communist Party Control: The Party's Hold on China's Medical Profession and Transplant Sector, published by the International Coalition to End Transplant Abuse in China (ETAC). Its central finding concerns who controls the institutions responsible for checking where donated organs come from: the same Party hierarchy runs hospitals, procurement organisations and much of the oversight structure.

The investigation also examined the publicly available 2016 membership list of the National Organ Donation and Transplantation Committee. It identified 17 confirmed CCP members among 33 committee members, slightly more than half. They included three representatives from the Red Cross Society of China and two from the Central Military Commission's Logistics Support Department.

China announced in 2015 that it would stop using prisoners as organ sources and rely on voluntary donations. Cook's investigation examines whether the institutions responsible for carrying out and checking that promise have enough independence to expose violations.

Published on October 20 as the first instalment in ETAC's Red Flags investigative series, the study draws on Chinese hospital websites, government documents, academic papers and an interview with a former doctor from Liaoning Province. Its series examines potential indicators of transplant abuse between 2020 and 2025.

The 19 profiles were selected through targeted research rather than a random survey, and include two people who had recently died. The findings describe documented individuals and institutions; the national proportion of transplant leaders who belong to the CCP remains unknown.

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Who Has the Final Say Inside Hospitals?

Party secretaries sit above hospital directors and clinical leaders in the governance structure described by the investigation. Their authority covers personnel, discipline and major institutional decisions. A hospital director may manage medical services, while the Party leadership controls decisions that shape how those services operate and who leads them.

CCP Central Committee directives issued in 2018 strengthened this arrangement in public hospitals, according to the study. Cook argues that political authority reaches across the transplant process, from identifying a possible donor to obtaining organs, reviewing ethical concerns, allocating organs and performing surgery.

Doctors who join the CCP also accept the Party's lifelong membership oath. Its commitments include carrying out Party decisions, observing discipline, protecting Party secrets and promising to "never betray the Party." The investigation argues that political obligations can carry stronger enforcement mechanisms than professional medical duties.

Wendy Rogers, chair of ETAC's International Advisory Board, said doctors' ethical responsibilities can be overridden by demands for Party loyalty. Her concern is practical: a clinician who believes a patient or donor has been mistreated must raise that concern within an institution whose political leaders also control careers and discipline.

National Oversight Follows the Same Hierarchy

The National Organ Donation and Transplantation Committee was established in 2013 by the health authorities and the Red Cross Society of China under State Council oversight. Its responsibilities include overseeing the China Organ Transplant Response System, the central digital platform used to allocate organs.

Huang Jiefu, a transplant surgeon and former vice minister of health, chaired the committee on its 2016 roster. A February 2026 publication continued to identify him as chairman. Cook's investigation also describes his CCP membership and former position as an alternate member of the Party's Central Committee.

The Red Cross Society of China has been presented as a third party in the donation process. The investigation describes it as a state supervised organisation under Party leadership. Its institutional position matters because checking donor consent requires the ability to challenge hospitals and officials when something goes wrong.

Professional associations follow a similar pattern. The investigation identifies Chinese Medical Association president Zhao Yupei and all 15 vice presidents appointed in 2021 as CCP members. It also describes embedded Party leadership in the Chinese Medical Doctor Association. These bodies therefore operate within the political structure overseeing the doctors whose conduct they may be expected to assess.

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How Organ Recovery Is Organised

China had 118 organ procurement organisations serving more than 180 qualified transplant hospitals in 2022, according to figures examined in the investigation. An organ procurement organisation, often called an OPO, coordinates the process of identifying donors and recovering organs for transplantation.

Chinese OPOs operate inside hospitals rather than as independent legal entities, the study says. Their management consequently falls within hospital leadership and its Party committee. Huang was also the founding head of the China OPO Alliance, established in 2014.

The comparison with the United States illustrates a concrete difference in institutional design. The investigation cites 54 independent nonprofit OPOs in the United States, with governing structures separate from transplant hospitals and exposure to federal investigation or loss of certification. China's 118 organisations operated within the hospital system.

Separating procurement from transplant surgery can help manage a basic conflict of interest: the people seeking an organ for a recipient should not control every decision about the potential donor. Cook argues that China's shared chain of command leaves too much authority inside the same institutions.

Hospital ethics committees are another part of that chain. These committees are supposed to examine whether medical activities meet ethical requirements, including consent and protection of vulnerable people. The investigation questions their independence and points to limited public disclosure about membership and practical obstacles to meaningful review.

What Happens When a Doctor Speaks Up?

A doctor who encounters suspected involuntary organ sourcing would first face the hospital's Party controlled authority structure, according to the investigation. Taking concerns outside the institution could bring Party discipline, detention through the liuzhi supervisory system or accusations of revealing state secrets.

Liuzhi is a form of detention used in China's supervisory investigations. Cook's report identifies the threat of detention and secrecy charges as part of the pressure that can discourage medical workers from reporting misconduct.

A former internal medicine doctor from Liaoning Province, now living outside China, described that fear in an interview used by the investigation. The doctor, whose name was not given, said:

If you yourself dare to speak up, you'd be the next to disappear.

The investigation also recounts a 2002 incident involving a Falun Gong practitioner brought to hospital with a broken pelvis. According to that account, authorities prevented necessary treatment and required staff to conceal the patient's presence. Cook uses the incident to illustrate how political orders can reach directly into medical care.

For a potential whistleblower, employment, personal safety and professional duties can therefore pull in different directions. The report calls for protection that allows doctors to report suspected abuse without depending on approval from the officials responsible for their institution.

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Why Xinjiang and Falun Gong Feature in the Findings

Wen Hao and Yang Yining are among the transplant officials identified in Xinjiang, where large numbers of Uyghurs have been detained. The investigation places their institutional roles alongside concerns about medical testing of detainees and the vulnerability of people held under state control.

Four other officials identified by the study worked at major hospitals in areas associated with extensive persecution of Falun Gong practitioners. Falun Gong is a spiritual practice involving meditation, exercises and moral teachings. The CCP began its campaign against the movement in 1999.

Zheng Shusen, a prominent transplant surgeon in Zhejiang Province, also held a leadership position in the Zhejiang Provincial Anti-Cult Association, an organisation involved in the campaign against Falun Gong. His profile connects a senior surgical role with participation in a political organisation targeting a group identified by the China Tribunal as a principal source of organs taken through coercion.

The investigation's concern centres on the combination of institutional access, political authority and vulnerable detainees. Its proposed response is closer examination of donor consent, procurement records and the ability of medical workers to report wrongdoing without punishment.

From the 2015 Reform Claim to the Tribunal's Findings

China's promise to rely on voluntary donations has shaped its renewed relationships with international transplant medicine. The China Tribunal later reached a sharply different assessment of past practices after examining allegations of forced organ harvesting.

The tribunal was an independent people's tribunal convened by ETAC, rather than a state court. It announced its conclusions in 2019 and published its full judgment in March 2020. It concluded that forced organ harvesting from prisoners of conscience had occurred on a substantial scale and identified Falun Gong practitioners as the principal source. It also identified evidence of medical testing of detained Uyghurs and concerns about their potential use as an organ source.

The main developments span more than a decade:

  • 2013: China's national organ donation and transplantation committee was established.
  • 2015: Chinese officials announced an end to using prisoners as organ sources and a shift to voluntary donations.
  • 2016: The publicly available national committee roster listed 33 members, 17 later identified by Cook's investigation as CCP members.
  • 2018: CCP directives strengthened Party leadership in public hospitals.
  • 2019 and March 2020: The China Tribunal announced its conclusions and subsequently published its full judgment.
  • 2022: Global Rights Compliance published legal guidance on risks associated with transplant collaboration involving China.
  • February 2026: A publication continued to identify Huang Jiefu as national transplant committee chairman.

Cook's study focuses on the institutions operating after the reform announcement and tribunal proceedings. Its central argument is that political control and weak protection for disclosure continue to obstruct reliable scrutiny of organ sourcing.

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International Cooperation Is Expanding

The formation of the International Society of Organ Medicine, announced on August 18, illustrates continuing international engagement. Its inaugural online meeting brought together 20 Chinese doctors and 20 international experts from six countries.

Huang Jiefu and John Fung, an American surgeon and president of the Transplantation Society, were named honorary presidents. The initiative places prominent figures from China's transplant system alongside international specialists at a time when questions about procurement and independent supervision remain central to the debate.

Sarah Cook, the researcher who wrote the ETAC study, described her concern in a statement accompanying the findings:

Every entity that Chinese officials present to international audiences as ostensibly independent or as a 'third party' is in fact a node in the same Party-controlled system.

Foreign hospitals, universities, journals and medical societies face concrete decisions about training surgeons, accepting research, sharing expertise and entering institutional partnerships. The 2022 legal advisory report and policy guidance from international law firm Global Rights Compliance had already flagged legal and human rights risks associated with transplant collaboration involving China.

What the Investigation Recommends

ETAC calls for separating CCP political authority from clinical decisions, creating transparent oversight and protecting people who expose wrongdoing. Those proposals address the central weakness identified throughout the investigation: institutions responsible for reporting and investigating abuse answer to the same political hierarchy.

For foreign governments, the report recommends legislation enabling sanctions and visa restrictions against people involved in organ trafficking, targeted sanctions and support for whistleblowers. It also proposes screening visiting Chinese transplant physicians for CCP affiliations as part of assessing their roles and institutional connections.

Medical organisations are urged to examine the governance of prospective partners as well as their scientific credentials. For a transplant collaboration, that means asking who verifies donor consent, who can investigate complaints and whether records can be checked outside the hospital's own chain of command.

Patients waiting for organs depend on a system that protects both recipients and donors. The investigation places responsibility on the institutions that approve partnerships and certify ethical practice to seek verifiable answers about consent, organ recovery and accountability.

Key Points

  • The ETAC investigation identified 19 CCP members among transplant leaders at 18 hospitals across 12 provinces or municipalities.
  • Six of those individuals also held senior hospital Party positions.
  • Seventeen of the 33 people on the publicly available 2016 national transplant committee roster were confirmed CCP members.
  • China had 118 hospital based organ procurement organisations serving more than 180 qualified transplant hospitals in 2022.
  • China announced a shift to voluntary organ donations in 2015. The China Tribunal later concluded that forced organ harvesting had occurred on a substantial scale.
  • The investigation calls for independent oversight, protection for whistleblowers and closer scrutiny of international transplant partnerships.
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