Over the past few decades, the pollutant emissions trading policies in China have undergone significant innovation and exploration. It is considered as a market-based approach that became integrated with command-and-control mechanisms such as total emissions control or pollution permits. This study is the first to provide systematic, reflective thinking that tracks the regional initiatives of pollutant emissions trading systems in China. In this article, we divided China's emissions trading practices into three stages and conducted a comparative qualitative analysis of the country's eleven provincial emissions trading pilots. We found that provincial pilots are highly diverse and complex regarding the pollutants that can be traded, the industrial sectors involved, the design of trading administration and processes, and the implementation of trading practices such as allowance, pricing and platforms. We also identified four main challenges: legislation setup, monitoring and verification, administrative interference, and the technical quantification of pollutant hotspots. We conclude the article by providing policy implications so that emissions trading policies can be integrated with the newly developed pollution permitting system.