National Implementation of the Kunming–Montreal Global Biodiversity Framework: A Comparative Law Perspective

Abstract

The Kunming–Montreal Global Biodiversity Framework (GBF) sets target-based and actionable commitments for the parties to the Convention on Biological Diversity (CBD) to facilitate its implementation. It is a strategic document that guides global biodiversity governance up to 2030 and beyond, including 2050. To achieve the 4 goals and 23 targets of the GBF, the parties to the CBD must adopt national biodiversity strategies and action plans, establish national targets, and strengthen their domestic biodiversity laws. By comparing China and the European Union’s (the EU’s) legal approaches to operationalizing the GBF targets, insights are obtained into how to improve both China and the EU’s national implementation of the GBF as well as the global collective implementation. Both China and the EU should formalize national targets and requirements as outlined in their respective policy documents. They also need to streamline legal frameworks and measures related to biodiversity and enhance the effective implementation of the legal measures, against the backdrop of China enacting its environmental code and the EU adopting the Nature Restoration Law.

1. Introduction

The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) reported in 2019 that nature and its vital contributions to people were deteriorating worldwide (IPBES 2019). Transformative changes are thus urgently needed to reduce and reverse biodiversity loss. The Kunming–Montreal Global Biodiversity Framework (GBF), adopted at the 15th Conference of the Parties (COP) to the Convention on Biological Diversity (CBD) held in December 2022, is an international instrument that aims to foster transformative changes. It sets the 2050 vision and 2030 mission for global biodiversity governance and is the latest strategic plan for implementing the CBD and its protocols. The CBD uses vague and noncommittal language and has developed qualified legal obligations, essentially rendering many provisions ‘soft’ (Smallwood et al. 2022). The GBF and its predecessor, the Aichi targets, take a target-based approach to elaborate on the requirements and actions necessary to fulfil the objectives of the CBD, which, as a framework convention, merely has general and abstract provisions. According to the fifth edition of Global Biodiversity Outlook and the COP Decision 15/3, the Aichi targets, which laid out the global biodiversity targets for the 2011–2020 period, were not fully achieved. The parties to the CBD leveraged the experiences and lessons learned from implementing the Aichi targets to draft and adopt the GBF (Maney et al. 2024). The GBF has four long-term global goals to be achieved by 2050 and 23 action-oriented global targets to be reached by 2030. Compared with the Aichi targets, the GBF is more ambitious and sets more quantifiable and actionable targets. One reason that explains the poor implementation of the Aichi targets is that national targets were not fully aligned with the Aichi targets, and national measures were not effectively implemented (Perino et al. 2022; Petersson and Stoett 2022; Secretariat of the CBD 2020). To avoid learning this lesson twice, the GBF has strengthened implementation tools and support measures (Hughes 2023). Enhanced national measures and concerted efforts at the national level are imperative to expedite the realization of the goals and targets of the GBF (Ferraro and Failler 2024). The emphasis on national implementation also aligns with the shifting focus in discussions regarding multilateral environmental agreements (MEAs) from rulemaking to implementation (Duvic-Paoli 2019).

There are heterogeneous patterns for the national implementation of the CBD and the GBF, as distinguished by various national biodiversity strategies and action plans (NBSAPs), national targets, and policy and legal frameworks (Maney et al. 2024). The parties to the CBD face the common challenges of providing solid legal foundations to achieve the goals and targets of the GBF (Carroll et al. 2022). This article will select China and the European Union (EU) as examples to analyze their legal approaches to implementing the GBF. China is one of the megadiverse countries (Bacon et al. 2019). The overexploitation of natural resources, driven by China’s large population, has caused the degradation of natural ecosystems and a decline in overall biodiversity (Li et al. 2021). China has therefore developed and implemented policies and laws to protect biodiversity (Liang and Zhuang 2024). The EU, on the other hand, relies heavily on ecosystem services offered by nature (Maes et al. 2021). The EU has built a legal framework to conserve and restore biodiversity (da Silva 2023), with the central instruments being the Nature Directives, which consist of the Wild Birds Directive (Directive 79/409/EEC, adopted in 1979 and was integrated into Directive 2009/147/EC in 2009) and the Habitats Directive (Council Directive 92/43/EEC, adopted in 1992), and the Nature Restoration Law (NRL, Regulation (EU) 2024/1991).

Both China and the EU have been incentivized by international obligations and guided by strategic policies on biodiversity conservation to develop and improve domestic biodiversity laws. They also face similar challenges such as transforming international requirements into domestic laws and reaching specific GBF targets in a more efficient and effective manner. Meanwhile, significant divergences exist between the legal systems of China and the EU, particularly within their specific approaches to biodiversity legislation, which is the focal point of this article’s discussion. For instance, multilevel legal systems are involved in China and the EU. China’s central government has been more active than its local governments in developing and implementing legal measures on biodiversity (Gu et al. 2025; Wang 2023), while the EU relies on its member states’ implementation (Wang 2023; Gehring et al. 2019). It is observed that there are territorial disparities and a lack of coordination among the EU’s member states regarding biodiversity conservation (da Silva 2023; Hermoso et al. 2022). More broadly speaking, the legal systems and institutional arrangements that provide bases for their respective biodiversity laws are fundamentally different. The EU, as a supranational organization, needs to balance the various interests and actions of its member states, as the EU’s competences are conferred by its member states. Moreover, the coordination of EU institutions is also crucial for the EU to effectively implement MEAs. By contrast, China has a centralized governance system, with less implementation barriers in this regard than the EU, though China has also faced challenges in the coordination between central and local governments. Against this backdrop, China and the EU have, respectively, established and explored effective regulatory instruments to address biodiversity issues, including protected areas, biodiversity offsetting, and nature-based solutions (Deng et al. 2021). Despite these differences, the literature has analyzed how the EU’s biodiversity governance inspired China, covering biodiversity mainstreaming, multilevel governance, monitoring and review mechanisms, international cooperation, and regulatory instruments (Deng et al. 2021; Wang 2023).

This article will discuss China’s and the EU’s approaches to promoting the achievement of the GBF targets from a comparative law perspective. A functionalist approach (Viñuales 2019) will be taken in the comparison to examine the measures employed by China and the EU to transpose the GBF targets in general and to implement specific GBF targets. The functionalist approach comprises identifying the problems, providing an interpretation of the laws as responses to the problems, comparing rules in different legal systems that can be interpreted as performing equivalent functions, and analyzing factors that affect the establishment and implementation of the relevant legal rules (Michaels 2019). A common problem discussed in this article is to what extent the Chinese and EU laws promote the effective implementation of the GBF. This is in fact a common challenge for many parties to the CBD (Santos et al. 2023). During the comparison and analysis, the commonalities and differences between China’s and the EU’s legal approaches towards implementing the GBF, and the reasons that explain the differences, will be analyzed.

The remaining parts of the article are structured as follows: Section 2 will provide a brief description of the goals and targets, as well as the national implementation requirements of the GBF. The analytical framework of the article will also be explained. Section 3 and Section 4 will compare China’s and the EU’s policy and legal frameworks for the implementation of the GBF targets. Specifically, Section 3 will discuss how national targets in China and the EU align with the GBF targets and are stipulated by legislation. Section 4 will analyze how legal frameworks and measures in China and the EU support and ensure the achievement of the goals and targets of the GBF. The discussion will address the backdrop of China enacting its environmental code and the EU’s adoption of the NRL. Section 5 will conclude this article with insights drawn from the comparison and suggestions for enhancing the national and collective implementation of the GBF, as well as the limitations of the article’s comparison.

2. The National Implementation of the GBF

2.1. The Goals and Targets of the GBF

Nations can take legislative, administrative, and judicial approaches to fulfill their international commitments in MEAs at the national level (Palmer 2021; Redgwell 2007). The legislative approach is especially important, which includes the process of translating international commitments into national laws (Escobar-Pemberthy and Ivanova 2020; Redgwell 2007). International commitments under the CBD, in general, refer to the three objectives of the CBD, i.e., the conservation of biodiversity, the sustainable use of its components, and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources. Substantive requirements of the CBD encompass, for instance, in-situ conservation (Article 8), ex-situ conservation (Article 9), the sustainable use of biodiversity components (Article 10), and the impact assessment and the minimization of adverse impacts (Article 14). The CBD stipulates support measures, including public education and awareness (Article 13), access to and transfer of technology (Article 16), technical and scientific cooperation (Article 18), and financial mechanism (Article 21). The GBF contributes to achieving the objectives of the CBD by setting concrete goals and targets in relation to these substantive requirements and support measures in Sections G and H. Meanwhile, the GBF outlines considerations for the implementation of the GBF in Section C, which include following a whole-of-government and whole-of-society approach, respecting national circumstances, priorities, and capabilities, and enhancing cooperation and synergies.

The first three global goals and the first 13 GBF targets directly contribute to achieving the three objectives and the substantive requirements mentioned above. For instance, GBF target 2 helps implement Article 8(f) of the CBD concerning ecosystem restoration, and GBF target 9 specifies requirements for promoting the sustainable management of wild species, as outlined in Article 10 of the CBD. Some GBF targets, such as GBF target 8, serve to fulfil obligations implicitly expressed by the CBD. GBF target 8 calls for synergetic governance of biodiversity and climate change, which represents an important aspect of international cooperation under Article 5 of the CBD. In other words, many GBF targets are rooted in specific provisions of the CBD and contribute explicitly to fulfilling the legal obligations set forth therein. Meanwhile, the fourth global goal (Global Goal D) and GBF targets 14 to 23 provide support measures, i.e., the tools and solutions for implementation and mainstreaming, necessary to realize the first three global goals and the first 13 global targets of the GBF. For instance, GBF targets 19 to 21 focus on financial mechanisms, capacity-building, and public participation, respectively.

2.2. National Implementation Requirements

Articles 6 and 26 of the CBD require the parties to develop NBSAPs, integrate biodiversity conservation into other sectors, and periodically report on the national implementation of the CBD. These implementation requirements have been elaborated on by Section J of the GBF, COP Decision 15/5 (Monitoring framework for the GBF, updated by Decision 16/31), and Decision 15/6 (Mechanisms for planning, monitoring, reporting and review, revised by Decision 16/32). Developing NBSAPs is specifically requested by Article 6 of the CBD. Conversely, the development of national targets is not explicitly stated in the CBD. According to Decision 15/6, NBSAPs are considered an umbrella process under which national targets and actions relevant to the GBF can be planned, implemented, monitored, reviewed, and enhanced. Thus, national targets need to be analyzed against the backdrop of the development and implementation of NBSAPs. NBSAPs usually have other parts than national targets, such as principles, roadmaps, concrete actions, and support measures regarding the implementation of the GBF. The relationship between national targets and NBSAPs resembles that between GBF targets and the GBF. Both NBSAPs and national targets are important connectors between international commitments and national legal measures that concretely implement the GBF. They have the potential to raise awareness of biodiversity issues, mobilize initiatives for biodiversity conservation, and foster accountability (Santos et al. 2023; Smallwood et al. 2022). National targets have been deemed integral parts of NBSAPs since 2011, and the parties to the CBD set national targets for the 2011–2020 period to promote the achievement of the Aichi targets (Smallwood et al. 2022). It is observed though that the potentials of these national targets were not fully exploited before 2020 (Reed et al. 2025; Xu et al. 2021). Based on the experiences of the Aichi targets, the GBF further highlights and enhances the planning, implementation, and review of national targets. Decision 15/6 encourages the parties to take an enhanced multidimensional approach to planning, monitoring, reporting and reviewing regarding the implementation of the GBF in a facilitative, non-intrusive, and non-punitive manner, involving revising and updating NBSAPs, communicating national targets, submitting national reports, and contributing to a global review of the GBF scheduled for COP 17 in 2026 (Carroll et al. 2022; Santos et al. 2023; Zhang et al. 2025).

To be specific, first, the parties had to publicize their NBSAPs and submit their national targets before COP 16, which commenced in October 2024. NBSAPs can be adopted as policy and/or legal instruments. Parties to the CBD should include explicit commitment to the overarching vision or mission of the GBF and avoid cherry-picking convenient GBF targets in their NBSAPs. For instance, it was observed that the submitted NBSAPs overemphasized GBF target 3 (Reed et al. 2025). The template for submitting national targets is provided in Annex I of Decision 15/6. Decision 16/31 contains headline, binary, component, and complementary indicators for the 4 global goals and 23 targets of the GBF, guiding nations designing national targets and reviewing the national implementation of the GBF. As explained in Annex I of Decision 15/5, headline indicators include a set of high-level indicators that capture the overall scope of the goals and targets of the GBF, binary indicators based on responses to yes/no questions will provide a count of the number of countries having undertaken specified activities, component indicators include a list of optional indicators that cover components of the goals and targets of the GBF, and complementary indicators include a list of optional indicators for thematic and in-depth analysis of each goal and target of the GBF. The Secretariat of the CBD also provides and regularly updates guidance notes for each GBF target to support the design of national targets (Secretariat of the CBD 2024). Key elements of each GBF target are explained in the guidance notes. As of 15 October 2025, 55 parties had submitted their NBSAPs to the Secretariat of the CBD and 140 parties submitted their national targets through the Online Reporting Tool (Online Reporting Tool of the CBD 2025). Since COP decisions are adopted by global consensus of the parties to the CBD, nations that aim to lead in global biodiversity governance tend to demonstrate greater commitment to translating GBF commitments into national laws (Zhang et al. 2025).

Second, the reporting and review mechanism serves to enhance the accountability of the parties and promote national implementation (Redgwell 2007). The mechanism will form an important basis for adjusting global goals and targets in the post-2030 decades. The parties are required to submit their seventh and eighth national reports by 28 February 2026 and 30 June 2029, respectively. The COP will subsequently review the global collective progress in implementing the GBF at COP 17 and COP 19. Annex I of Decision 16/32 provides a template to assist in preparing national reports. These reports will describe and analyze in depth the parties’ implementation of NBSAPs and national targets. The GBF is adopted as a COP decision under the CBD and is therefore considered a soft law instrument without legally binding force (Buckley 2023; Streck 2023). The reporting and review mechanism helps ensure compliance with the GBF’s non-binding targets, thereby creating indirect normative force for the GBF (Smallwood et al. 2022; Streck 2023).

2.3. Analytical Framework

The EU and China had updated NBSAPs in 2020 and 2024, which are the EU Biodiversity Strategy for 2030 and China National Biodiversity Conservation Strategy and Action Plan (2023–2030) (hereinafter referred to as China’s NBSAP (2023–2030)), respectively, and communicated their national targets via the Online Reporting Tool of the CBD before COP 16. Following the adoption or updating of NBSAPs and national targets, functioning domestic legal frameworks and legal measures on biodiversity are indispensable (Prakash and Liquete 2023; Qi et al. 2023; Santos et al. 2023; da Silva 2023; Zinngrebe 2023). Moreover, to better implement the international and national commitments on biodiversity conservation, certain policy commitments should be transformed into legislative acts (Wang and Liu 2023). This is firstly based on the lessons acquired by the parties to the CBD when implementing the Aichi targets. For instance, the EU’s adoption of the NRL is the result of the reflection on the limitations of the previous implementation of the non-binding commitments on nature restoration: despite the establishment of national targets in this area, these targets lacked legally binding force, and the corresponding legal measures enacted to ensure their achievement were insufficient (Sowery 2024). Secondly, an environmental rule of law is necessary for addressing environmental issues, which requires the development of legally binding rules that establish standards, procedures, rights, and obligations (United Nations Environment Programme 2019). Both the NBSAPs of China and the EU are non-legally binding documents, but they are also supported and strengthened by a series of laws and regulations. It should be noted that both NBSAPs confirm that the legal frameworks and measures require further improvement. With the guidance of China’s NBSAP (2023–2030), China aims to establish a basic legal and policy system for biodiversity conservation by 2030 and to further improve this system comprehensively by 2035. Similarly, according to Section 3.1 of the EU Biodiversity Strategy for 2030, the EU needs to establish a comprehensive governance framework to facilitate the implementation of biodiversity commitments agreed upon at national, European, and international levels.

Member states of the EU are all parties to the CBD and thus committed to transforming GBF commitments into their national policies and laws. Each member state needs to make and implement its own NBSAP and a set of national targets. The effective implementation of the NBSAPs and national targets at the EU level will not be achieved if the actions of the member states are not well coordinated (Althouse et al. 2023). As of 15 September 2025, 13 member states have submitted NBSAPs to the Online Reporting Tool of the CBD, and the number for member states submitting national targets is 17. Eleven member states submitted NBSAPs and national targets before the EU did so, and some countries, such as the Netherlands, Malta, and Hungary, updated their NBSAPs and communicated their national targets after the GBF was adopted. As member states set and implement their NBSAPs and national targets under the guidance of the EU Biodiversity Strategy for 2030 and the national targets collectively set by all EU member states, the article will focus on the NBSAPs and national targets at the EU level.

The lack of effective implementation of MEAs is a well-documented issue, as confirmed by UN reports and the academic literature (UN Secretary-General 2018; United Nations Environment Programme 2019; Steinar 2021). Scholars have identified a range of factors that hinder the effective implementation of MEAs in general, and the CBD in particular (Hao et al. 2023; Steinar 2021; Palmer 2021; Le Prestre 2017). These factors encompass convention governance systems, political willingness, capacity-building, monitoring and compliance mechanisms, transparency, and the involvement of non-state actors. Within this context, enhancing national regulatory capacities through the enactment and implementation of robust national domestic environmental laws is recognized as a critical pathway to promote the effective fulfillment of MEA obligations (Nanda and Pring 2012; Núnez-Rocha and Martınez-Zarzoso 2019). China and the EU have proved their determination to lead global biodiversity governance by proposing and promoting more ambitious GBF targets, updating NBSAPs and national targets in a timely manner, and developing legal frameworks and measures to fulfil their international commitments (Aubert et al. 2023; Zhang et al. 2025). The national implementation of the GBF by major powers such as China and the EU significantly shapes its global implementation (Zhang et al. 2025). A comparison of these parties’ national implementation of the GBF would offer globally relevant policy insights as to how to align national policies and laws to global targets and how to enhance the effective implementation of the GBF (Maney et al. 2024; Carroll et al. 2022; Duvic-Paoli 2019). A critical principle in comparative environmental law is that legal models are deeply embedded in their specific contexts; therefore, presuming a model can be transplanted in toto to another jurisdiction risks ineffectiveness, as it presumes a degree of uniformity in legal traditions, socioeconomic conditions, and institutional capacities that rarely exists (Lees 2019). Thus, the article’s aim is not to present a straightforward analysis of transplanting laws and measures (Watson 1974) between China and the EU, but rather to explore how their respective approaches to biodiversity legislation can serve as a source of mutual inspiration for implementing the CBD and the GBF, as well as to discuss potential pathways for enhancing their domestic legal frameworks.

The following two sections will analyze, from a comparative law perspective, the extent to which the GBF has been implemented by China and the EU. The formalization of GBF targets and the development of legal frameworks and legal measures that support the realization of the GBF and national targets will be discussed, respectively, in Section 3 and Section 4. When analyzing to what extent a GBF target is formalized, i.e., to what extent legislation is aligned with a target, three questions need to be answered: (1) How are GBF targets translated into national targets in China and the EU? (2) To what extent are these targets legalized? This involves determining if legislation duplicates the targets or comprehensively incorporates their elements. While incorporating the GBF targets verbatim into law might appear to strengthen their legal force, this can result in lengthy, repetitive legislation, as key concepts like sustainable management of wild species appear across multiple targets (e.g., GBF targets 5 and 9). A more effective approach is to move beyond literal transcription and instead translate the core tenets of the GBF targets into specific and actionable legal clauses. The objective should be a legal framework where all elements of the GBF are seamlessly woven into the fabric of domestic law, ensuring comprehensiveness without redundancy. (3) If legalization is partial, how can key elements of the targets be systematically embedded within the broader legal framework? The third question is contingent on the findings of the second. GBF targets 1 to 13 will be mainly analyzed, as they contain the key substantive requirements for biodiversity conservation and restoration, provide direct guidance on how to halt and reverse biodiversity loss, and thus hold a central position when parties to the CBD endeavor to achieve the CBD’s objectives.

Furthermore, as will be analyzed in Section 4, the prerequisite for systematically translating all elements of the GBF targets into legal rules is the establishment of a coherent legal framework on biodiversity. Moreover, following the adoption of domestic biodiversity legislation that promotes the implementation of the CBD and the GBF, emphasis must be placed on the enforcement of relevant domestic laws and regulations. Coordinated implementation, monitoring, and review of the progress in GBF implementation, robust funding mechanisms, along with sufficient public involvement, will facilitate the achievement of both the GBF and national targets (Zhang et al. 2025; Hutchinson et al. 2025; Rich 2025; Ferraro and Failler 2024; Li 2023); these aspects will also be analyzed in Section 4. Comparing China’s and the EU’s implementation of the GBF from these two perspectives will not only reveal how laws on paper incorporate GBF requirements but also help indicate—or even predict—the extent to which the vision and missions of the GBF can be realized under current domestic legislation.

3. National Targets and Their Formalization

Of the three key questions to be answered in this section, the first involves assessing the alignment between national targets and the GBF targets. This assessment is guided by the definitions provided in Decision 15/6: a high alignment means that a national target a national target comprehensively encompasses all elements of the corresponding GBF target, a medium alignment indicates that it covers most of the elements, and a low alignment is assigned when at least one element, but not most, of the key elements is addressed. The second area of analysis examines the integration of the GBF targets into domestic legislation. The alignment of national biodiversity laws with the GBF and the nationally set targets is evaluated using a similar tiered approach. Here, high alignment is characterized by domestic laws or regulations that incorporate the key elements of a GBF target. Medium alignment is determined when these legal instruments cover most, but not all, of the critical components of the GBF target, while low alignment is concluded if few or none of the elements are reflected in legislation. The specific elements used for this evaluation are derived from the guidance notes issued by the CBD Secretariat (Secretariat of the CBD 2024), ensuring a consistent benchmark across different targets. Finally, a comparative analysis of the improvement pathways undertaken by China and the EU to systematically incorporate the GBF and national targets into legislation is conducted against two primary criteria: whether the pathways establish a general legal basis for addressing biodiversity issues, and whether the specific actions directly contribute to advancing the implementation of the GBF.

3.1. China

The China National Biodiversity Conservation Strategy and Action Plan (2011–2030) was adopted in September 2010 and then updated in January 2024 to China’s NBSAP (2023–2030). Although China’s NBSAP (2023–2030) is not legally binding, it serves as a guiding document that outlines China’s objectives and measures for implementing the CBD and the GBF. It delineates 27 priority actions and 75 priority projects, covering four priority areas, namely, mainstreaming biodiversity, addressing threats to biodiversity loss, sustainable use and benefit-sharing about biodiversity, and strengthening biodiversity governance capacities (China Releases National Biodiversity Conservation Strategy and Action Plan (2023–2030) 2024). China submitted its national targets on 6 September 2024 (CBD Secretariat 2025a). These national targets are directly derived from the priority actions identified by China’s NBSAP (2023–2030), with each priority action corresponding to one national target. All GBF goals and targets are reflected by China’s national targets: at least one national target is set to realize each goal or target of the GBF. For instance, GBF target 1 on spatial planning is to be realized through priority actions 1 (improving the policy and legal system on biodiversity) and 7 (optimizing ecological space) in China’s NBSAP (2023–2030). It is important to note that biodiversity conservation and restoration in China are guided not only by the NBSAP (2023–2030) but also by several other key national strategies, which serve as crucial foundations for its implementation. For example, Chapter 37 of the Outline of the 14th Five-Year Plan (2021–2025) for National Economic and Social Development and Vision 2035 of the People’s Republic of China outlines priority areas for biodiversity protection, including enhancing the ecological security shield system, expanding China’s protected area network, and improving the ecological compensation mechanism. Furthermore, the Opinions of the Central Committee of the Communist Party of China and the State Council on Further Strengthening Biodiversity Conservation, issued in October 2021, set out overarching requirements such as improving the legal framework for biodiversity, establishing a robust monitoring system, strengthening law enforcement, and deepening international cooperation.

Headline and binary indicators, rather than component or complementary indicators, have been used to monitor and review each national target in China. This approach aligns with Paragraph 8 of Decision 15/6, which requests that parties to the CBD use headline and binary indicators while voluntarily incorporating component and complementary indicators. Additionally, Decision 15/6 encourages the parties to describe the main implementation measures or actions, as well as the commitments made by non-state actors, towards each national target. China did not provide information on these optional elements when submitting its national targets. Finally, Decision 15/6 requires parties to specify the degree of alignment between their national targets and the GBF targets. China reported that its national targets are highly aligned with 16 GBF targets, while moderately aligned with 7 GBF targets. For instance, China’s national targets related to the conservation of threatened species and the sustainable management of wild species are in medium alignment with GBF targets 4 and 9. Jiang et al. (2025) revealed a significant disparity in the alignment of China’s national targets with the GBF, noting that four and nine targets were found to be at a medium and low level of alignment, respectively, highlighting a crucial challenge. According to their assessment, GBF targets 3, 7, 9, and 13 were assessed as having a medium level of alignment, whereas target 11 was ranked at a low level (Jiang et al. 2025).

China has enacted various laws and regulations concerning biodiversity. These legal instruments can contribute to achieving the GBF targets, as they address all three objectives of the CBD—namely, the conservation of ecosystems, species, and genetic resources—while the extent to which each objective is sufficiently addressed varies. To illustrate, first, the National Park Law (NPL, adopted in 2025 but not yet effective) stipulates the procedures and requirements for designating and managing national parks and includes provisions to promote international cooperation in this field (Article 11). The NPL, upon its effective date, will directly contribute to fulfilling the 30 by 30 conservation target as outlined in GBF target 3 by establishing a legal framework for the systematic expansion and robust protection of China’s protected areas. More specifically, Article 34 of the Marine Environmental Protection Law (MEPL, adopted in 1982 and revised in 2023) mandates the integration of marine protected areas into the national protected area system—comprising national parks, nature reserves, and natural parks—a measure that directly supports the achievement of GBF target 3. Second, the Wildlife Protection Law (WPL, adopted in 1988 and revised in 2022) aims to conserve wildlife, save rare and endangered wildlife, maintain biodiversity and ecological balance, advance ecological civilization, and promote the harmonious coexistence between human beings and nature. Wildlife protected under the WPL (Article 2) refers to rare and endangered terrestrial and aquatic wildlife species and terrestrial wildlife with significant ecological, scientific or social values. The WPL thus relates to GBF targets 4, 5, and 9. Lastly, the Biosecurity Law, as adopted in 2020 and revised in 2024, covers the utilization of genetic resources as requested by GBF target 13. It protects the ecological environment and promotes the harmonious coexistence of man and nature from the perspective of preventing various biosafety risk factors such as animal and plant epidemics, the development and utilization of genetic resources, and the threat of biological weapons. However, it should be noted that the specific ways in which the access and benefit-sharing (ABS) regime established by the Nagoya Protocol will be applied and implemented within China remain unclear, as its core principles, supporting measures, responsible institutions, and legal liabilities require further clarification (Liu 2025b).

Based on the criteria explained above, China’s biodiversity legislation demonstrates a low to medium alignment with the GBF targets, as it covers few or none of the key elements specified for each target. First, some GBF targets are merely mentioned in policy documents rather than being mandated by any laws on biodiversity, such as GBF targets 8 (on synergetic governance of biodiversity and climate change) and 11 (on restore, maintain and enhance nature’s contributions to people) (Jia and Zhang 2024). Taking GBF target 8 as an example, effective environmental law is important for enhancing the synergetic governance of biodiversity and climate change (Pörtner et al. 2021). A climate law, covering, for instance, nature-based solutions, which facilitate the synergetic governance of climate change and biodiversity, has not yet been enacted in China (Chen 2022). Second, some GBF targets, such as targets 2, 6, and 12, align to the medium degree with Chinese laws and regulations on biodiversity. Taking GBF target 2 as an example, both GBF target 2 and priority action 8 in China’s NBSAP (2023–2030) require that by 2030, at least 30% of areas of degraded terrestrial, inland water, and marine and coastal ecosystems are under effective restoration. Although quantified restoration commitments are not stated in any Chinese legislation, the restoration of degraded ecosystems has been requested by several legal provisions, such as Article 32 of the Environmental Protection Law (EPL, revised in 2014), Article 42 of the MEPL, and Article 37 of the Wetlands Conservation Law (WCL, adopted in 2021). Another example is GBF target 1. Article 12 of the revised MEPL echoes the policy commitments stated by GBF target 1 and priority action 7 of China’s NBSAP (2023–2030) regarding marine spatial planning. However, the key elements requested by GBF target 1 such as participatory, integrated, and biodiversity inclusive spatial planning and effective management processes are not fully presented by Article 12 (Liu 2025a).

Since the legalization is partially done, more effort is needed to systematically integrate policy commitments into legislation. The aim, instead, should be that all elements of GBF targets or national targets be systematically incorporated into legal provisions. This relates to the third questions mentioned above, involving the enactment of general clauses on biodiversity conservation and an explicit statement on compliance with international obligations. Article 6 of the EPL sets the obligation to protect the environment for state and non-state actors and specifically requests that governments be responsible for improving the quality of the environmental. Biodiversity conservation is one of the key actions for maintaining an acceptable level of environmental quality. Article 30 of the EPL further provides a general requirement on biodiversity, stipulating that measures must be taken to conserve biodiversity in the development and utilization of natural resources, the introduction of alien species, and the application of biotechnology. Nonetheless, there is a lack of a clause that comprehensively covers all three objectives in the CBD (ecosystems, components, and genetic resources). The enactment of the environmental code, the draft of which has been released for public comments (Xinhua 2025), provides an opportunity for China to establish a series of general and specific clauses that contain objectives on biodiversity conservation, as well as legal obligations to comply with international commitments on biodiversity. On the one hand, Article 1 of the draft environmental code sets the general objectives for environmental protection, one point of which is ecological conservation. Moreover, Section 3 of the draft environmental code focuses on biodiversity conservation, comprising 7 chapters that cover general provisions, ecosystem conservation, the conservation and sustainable use of natural resources, species protection, the protection of geographical areas, and the prevention and restoration of degraded ecological environments. The adoption of an environmental code would serve as a major catalyst for integrating the GBF into national law. This would not only incorporate a greater number of GBF targets into binding legal rules but also directly translate into a higher level of alignment between China’s biodiversity legislation and the GBF. On the other hand, Article 14 requests China implement the obligations contained in MEAs. This provides a legal basis for China to implement the CBD.

3.2. The EU

The EU submitted 45 national targets on 10 August 2024 via the Online Reporting Tool, covering actions and measures that promote all the 4 goals and 23 targets of the GBF (CBD Secretariat 2025b). Compared to China, the EU provided more granular data on its national targets, including the laws and policies that implement these targets, the involvement of non-state actors in relation to the targets, and the component and complementary indicators for each target. When submitting its national targets, the EU identified the primary legislation, proposed legislation, and policy instruments that support the achievement of each national target. Meanwhile, the roles of non-state actors in implementing national targets corresponding to GBF targets 8, 11, and 14 are specifically detailed. In addition, the EU has set more quantified national targets than China: beyond GBF targets 2, 3, and 6, it has also established quantified targets for GBF targets 7, 8, 16, and 19. The EU reports that all its national targets are highly aligned with the GBF’s goals and targets, meaning they comprehensively reflect all elements thereof.

The EU’s latest NBSAP, i.e., the EU Biodiversity Strategy for 2030, contains national targets; however, unlike in China, it is not the only source of the EU’s national targets (Directorate-General for Environment 2024a). Policy documents on biodiversity conservation in the EU are arranged in a pyramid structure, with the highest being the European Green Deal and environmental action plans, NBSAPs in the middle, and sectoral plans below (de Sadeleer 2017). The European Green Deal, adopted in 2019, is an integral part of the EU’s strategy to achieve sustainable development goals (Mattalia 2024). Section 2.1.7 of the European Green Deal explains the necessity and legal approaches to preserving and restoring ecosystems and biodiversity. It takes the adoption of the GBF as an opportunity to comprehensively address the EU’s biodiversity issues and promote the EU’s role in global biodiversity governance. The European Green Deal has triggered a wide range of initiatives and policies on topics such as climate change, just transitions, and biodiversity protection (Petersmann 2024). Meanwhile, the 8th Environmental Action Plan (Decision (EU) 2022/591), adopted in 2022, sets the protection, conservation, and restoration of biodiversity as one of its six priority objectives. As the 8th Environmental Action Plan takes the form of decisions, the aforementioned objective is legally binding. Thus, EU legislators have translated the European Green Deal’s biodiversity conservation policies into binding mandates.

Based on lessons learnt from the EU Biodiversity Strategy for 2020, the EU Biodiversity Strategy for 2030 sets out goals and actions across four key areas to be achieved by 2030: establishing a coherent network of protected areas, restoring ecosystem on land and at sea, enabling transformative change through a new biodiversity governance framework and strengthening implementation and enforcement of EU environmental legislation, and promoting global biodiversity governance. The EU Biodiversity Strategy for 2030 is a central policy document that takes an integrated approach, linking biodiversity conservation with climate change and sustainable development goals, and recognizes the need for cross-sectoral policy integration (Torrance and Tomlinson 2025). Nature protection and nature restoration are elaborated on by 3 and 14 key commitments, respectively. A number of quantified targets presented by the key commitments of the EU Biodiversity Strategy for 2030 were later incorporated by the GBF. For instance, the first key commitment for nature protection in the EU Biodiversity Strategy for 2030 reiterates the 30 by 30 conservation target, as outlined in GBF target 3. This demonstrates the EU’s ambition to lead the global biodiversity governance. Lastly, several sectoral policies have incorporated biodiversity conservation requirements. For instance, the Zero Pollution Action Plan, adopted in May 2021, sets the 2030 targets that promote GBF target 7; the New EU Forest Strategy for 2030, adopted in July 2021, sets the roadmap for promoting sustainable forest, contributing to the achievement of GBF target 10. Sectoral plans are important tools to mainstream biodiversity targets into sectors such as pollution control, agriculture, and forest management.

The aforementioned policy documents demonstrate the EU’s commitment and ambition to promote biodiversity governance both within and beyond its borders. Such commitment and ambition are further bolstered by biodiversity laws in the EU that facilitate the achievement of the GBF targets. A salient feature of the EU’s approach to translating GBF commitments into legislation is that several legislative acts, such as the NRL, have explicitly incorporated certain elements of the GBF targets. By enacting regulations and directives, the EU has legalized political objectives on biodiversity, thereby transforming soft law requirements into binding legal obligations (Ferroni 2024). To illustrate, first, the EU has transformed GBF targets 1, 2, 11, and 12 into legislation by adopting the NRL. The NRL was adopted in June 2024 and came into effect in August of the same year, and it sets legally binding targets on nature restoration (Hering et al. 2023). It is based on one of the lessons of implementing the restoration targets set out by the EU Biodiversity Strategy for 2020, which finds that a lack of legally binding restoration objectives or commitments led to a poor implementation of international and the EU targets on biodiversity restoration (Sowery 2024). The NRL is the first law to cover the European continent and implement a comprehensive nature restoration approach. It represents a paradigm shift from an anthropocentric to an eco-centric approach (Ferroni 2024; Sowery 2024). Fulfilling the obligations in the CBD and achieving the goals and targets of the GBF, especially GBF targets 1 (Plan and manage all areas to reduce biodiversity loss), 2 (Restore 30% of all degraded ecosystems), and 11 (Restore, maintain and enhance nature’s contributions to people), are emphasized in the preamble of the NRL. Moreover, Article 1(1) of the NRL stipulates that fulfilling international commitments is one of its general objectives. To be specific, based on Article 1(2) of the NRL, the EU has to put in place effective and area-based restoration measures that cover at least 20% of the EU’s land and sea areas by 2030, and all ecosystems in need of restoration by 2050. Quantified and time-bound restoration targets for different types of ecosystems such as forest, marine, freshwater, and urban ecosystems are also stipulated by the NRL in its Articles 4, 5, and 8 to 13 (Directorate-General for Environment 2024b). Additionally, Article 6 of the NRL aims to set obligations for the member states regarding the maintenance of urban green space. Nonetheless, it should be noted that the decrease in the quantified target from 30% to 20% of restored areas shows that the EU lessened its initial ambition and to a certain extent lessened the impact of the NRL (Aggestam 2024; Hoek 2022).

Second, several pieces of legislation, adopted before the GBF, have legal rules that promote the achievement of the GBF targets. The Nature Directives support the achievement of the EU’s national targets that correspond to GBF targets 1 to 6, 9, and 10. They help increase and manage protected areas through Natura 2000 sites, which consist of special protection areas and special areas of conservation, with the core tool being environmental impact assessment. They directly contribute to the achievement of the 30 by 30 conservation target as stated by GBF target 3. As of January 2024, Natura 2000 covered more than 18% of the EU’s land area and approximately 9% of its marine area, being the world’s largest network of protected areas (BISE 2025). The Invasive Alien Species Regulation (Regulation (EU) No 1143/2014), Climate Law (Regulation (EU) 2021/1119), and ABS Regulation (Regulation (EU) No 511/2014) have legal rules that cover all or only parts of the key elements of GBF targets 6, 8, and 13. The Invasive Alien Species Regulation sets out rules to prevent, minimize, and mitigate the adverse impact on the biodiversity of the introduction and spread within the EU of invasive alien species. Article 1(1)(a) of the NRL and Article 5(4) of the Climate Law will contribute to fulfilling the requirements of GBF target 8 regarding minimizing negative and fostering positive impacts of climate action on biodiversity and GBF target 11 on nature-based solutions and/or ecosystem-based approaches. Regarding the regulation of genetic resources, the ABS Regulation implements the Nagoya Protocol’s obligation to monitor users’ compliance and directly promote the achievement of GBF target 13.

Although all GBF targets are more or less covered by the EU legislation on biodiversity, not all key elements of these targets are stipulated by the relevant pieces of legislation. For instance, the quantifiable targets in GBF target 3 (the 30 by 30 conservation target) and GBF target 6 (the reduction in the rates of the introduction and establishment of invasive alien species by 50% by 2030) are not stated in the Nature Directives and the Invasive Alien Species Regulation. Regarding GBF target 13, access to genetic resources remains within the competence of EU member states (Klunker and Richter 2022). Moreover, there is no EU special law regulating the access and benefit sharing of digital sequence information, which is especially emphasized by the GBF (Klunker and Richter 2022).

As shown above, current legislation in the EU does not completely incorporate the key elements of GBF targets. The incorporation of general objective clauses that explicitly reference the vision and missions of the GBF could provide a crucial interpretive basis for policymakers and courts. Such clauses would offer a consistent legal basis for aligning existing and future EU measures with the GBF’s overarching ambitions, thereby bridging gaps where specific transposition is incomplete. The EU has several legal provisions that directly mandate the solving of global environmental problems. According to Article 191(1) of the TFEU, the EU’s policies and laws on environmental protection shall contribute to ‘promoting measures at international level to deal with regional or worldwide environmental problems, and in particular combating climate change’. Although ‘biodiversity’ is not directly mentioned, ‘regional or worldwide environmental problems’ obviously include global biodiversity governance issues. The implementation of the GBF is thus covered. Several pieces of the EU secondary legislation also take the fulfilment of international obligations as one of their objectives or include provisions for international cooperation. Such provisions include Article 1(1)(d) of the NRL, Article 1 of the Council Regulation (EC) No 338/97 on the Protection of Species of Wild Fauna and Flora by Regulating Trade Therein, Article 1 of the Regulation on Deforestation-free Products (Regulation (EU) 2023/1115), and Article 22 of the Invasive Alien Species Regulation. These provisions will, on the one hand, facilitate the implementation of the GBF in the EU, and, on the other hand, increase the EU’s influence on global biodiversity governance (Laurent et al. 2014).

3.3. Analysis

China and the EU have set and publicized their national targets, encompassing all the goals and targets of the GBF. As presented by

Table 1. The formalization of GBF targets in China and the EU.

Dimensions		China	The EU
National targets	Dates when national targets were submitted	6 September 2024	10 August 2024
	Number of national targets	27	45
	Sources of national targets	China’s NBSAP (2023–2030)	NRL, EU BDS, and sectoral plans
	Headline and binary indicators	Provided	Provided
	Component and complimentary indictors, main implementation measures or actions, and the commitments of non-state actor	Not provided	Provided
	Alignment with GBF targets	16 GBF targets highly aligned with, and 7 mediumly aligned with	All highly aligned with
Translation of national targets into legislation	Incorporating national targets verbatim into relevant legislation	Partially done	Partially done
	Covering the key elements of national targets	Partially done	Partially done
Systematic presentation of GBF and national targets	General clauses on biodiversity conservation and restoration	Article 30 of the EPL	NRL and Nature Directives
	General clauses on the implementation of MEAs	The draft environmental code	Article 191(1) TFEU

above, compared to China, the EU has provided more details of its national targets, including component and complementary indicators, as well as implementing policies and legislation, and commitments from non-state actors. These details are optional items when the parties to the CBD communicate their national targets to the Online Reporting Tool. The EU’s national targets are derived from several policy documents and legislation, such as the EU Biodiversity Strategy for 2030, the Zero Pollution Action Plan, and the NRL. China’s national targets, by comparison, are more centralized as they are stated in a single document, i.e., China’s NBSAP (2023–2030).

There is a common challenge for China and the EU to translate all key elements of the GBF targets systematically into legal provisions. The national targets are translated into legal objectives and legal rules to different degrees. In China, some elements of GBF targets are stipulated in legislation such as the EPL, MEPL, and WCL. However, the EPL only provides an abstract mandate, while other legislation, such as the MEPL and the WCL, is not universally applicable as it focuses on specific ecosystem types (e.g., marine environments and wetlands, respectively). In the EU, the most comprehensively transposed target is GBF target 2 on nature restoration. The NRL outlines the general objective of restoring degraded ecosystems, as well as the time-bound and quantified objectives for specific ecosystems. This resembles the process of transforming climate change goals into legal goals by the EU Climate Law (Penca and Tănăsescu 2025). It essentially involves translating soft law commitments into legally binding obligations (Ferroni 2024). Meanwhile, the EU’s Nature Directives, Invasive Alien Species Regulation, Climate Law, and ABS Regulation are backbone acts that implement the GBF targets. In short, the GBF targets are not completely transformed into legal provisions in neither China nor the EU. However, compared with China, the EU has more GBF targets, the key elements of which are included in its legislation. In other words, the alignment of legislation with GBF targets in the EU is higher than that of China.

Legislators need to first identify elements that are not covered by legislation on biodiversity and then propose to adopt or revise the relevant legal rules. In addition to codifying individual targets into the legal framework on biodiversity, general objective clauses should be stipulated to mandate the overall achievement of all GBF targets. Explicit legal commitments to achieving the collective GBF targets at the national level can avoid fragmented response to biodiversity issues and enhance the effectiveness of the implementation of the GBF (Reed et al. 2025). Furthermore, enhancing the legal basis for participating in global biodiversity governance is a crucial approach to strengthening the national implementation of the GBF. Participating in global biodiversity governance is also a requirement of the principle of international cooperation (Zhang et al. 2025). A general objective clause is necessary to mandate the overall commitment to implementing the GBF; however, such a clause is not explicitly stated in Chinese or EU legislation. Articles 6 and 30 of the EPL provide legal bases for China taking legal measures to conserve and restore biodiversity. Similarly, the EU’s secondary legislation, such as the Nature Directives, mandates the EU to take measures to preserve biodiversity and thus is an important legal basis to implement the GBF in the EU. Both China and the EU do not have a specific biodiversity law that directly states that legal measures must be taken to realize the vision or mission set by the GBF. China has moved towards enacting specialized and comprehensive general clauses on biodiversity, while the EU is more advanced in explicitly mandating the compliance and implementation of MEAs. China’s draft environmental code offers opportunities to incorporate the general clause on biodiversity conservation and more national targets into legislation. The EU’s legal requirements regarding the fulfilment of international commitments are important references for China enhancing its legal basis in this regard.

4. National Legal Frameworks and Measures That Support the Implementation of the GBF

The analysis in this section commences with an assessment of the relevant legal frameworks and proceeds to evaluate how monitoring and review mechanisms form the foundation for implementing the GBF. From a legal perspective and considering the complexities of the GBF and national targets, the monitoring and review of the implementation of laws and regulations on biodiversity need to be analyzed. Establishing a robust compliance monitoring framework, which includes ongoing oversight and systematic reporting, is a fundamental component for verifying compliance, assessing the effectiveness of measures, and enabling adaptive management in biodiversity governance. The GBF targets are achieved through implementation tools and support measures such as the reporting and review mechanism. Similarly, at the national level, developing and improving systematic national laws and regulations on biodiversity conservation must be followed by their effective implementation, as will be promoted by national monitoring and review measures.

4.1. China

China has established and implemented legal measures that promote the implementation of the CBD and the GBF. However, the current biodiversity measures are not organized in a consistent and comprehensive manner, since they are scattered in different laws and regulations, adopted to fit for different purposes (Qin 2020, 2021). Legal rules on biodiversity range from the constitution to laws adopted by the NPC or its standing committee, such as the EPL, the NPL, the MEPL, the Biosecurity Law, and the WPL, to regulations adopted by the State Council or local people’s congresses (Qin and Liu 2022; Yu and Hu 2022). At the local law level, Yunnan, Shandong, and Jiangsu Provinces adopted their regulations on biodiversity in 2018, 2023, and 2025, respectively. To streamline the fragmented legal provisions, a holistic system approach should be taken by the NPC or its standing committee to adopt a comprehensive and special biodiversity law (Li 2023; Qin and Tian 2021; Wang and Liu 2023; Yu and Hu 2022).

The draft environmental code outlines general objectives, legal principles, and measures for biodiversity conservation and restoration. These provisions are derived from several existing laws and regulations related to biodiversity. Taking nature restoration as an example, the principle of natural restoration taking precedence over and being supplemented with artificial repair has been provided for by Article 52 of the Yangtze River Protection Law (adopted in 2020), Article 37 of the WCL, Article 29 of the Yellow River Protection Law (adopted in 2022), and Article 42 of the MEPL. These provisions are generalized into Article 32 of the draft environmental code. Articles 32 and 670 also require the government to strengthen nature restoration and adhere to the principle of integrated conservation and restoration for mountain–river–forest–farmland–lake–grass ecosystems. Such a holistic systems view is consistent with the GBF’s ecosystem approach and the ecosystem-based approach. Additionally, the draft environmental code includes new legal provisions that were not previously stipulated. For instance, the utilization and benefit sharing of genetic resources are regulated by Article 678 of the draft environmental code. The enactment of the environmental code presents an opportunity to restructure laws and regulations related to biodiversity. Once the environmental code is adopted, a legal framework will be established that covers more substantive requirements of the GBF, though the question regarding how the legal measures established by the environmental code connect with other specific laws and regulations related to biodiversity should be answered.

The question that follows the adoption of the environmental code is how legal measures can be effectively implemented. China’s NBSAP (2023–2030) (Section 2 of Chapter 2) specifically points out that biodiversity monitoring network and methods are not sufficient, and the supervision and management of biodiversity still need to be improved for lack of coordination among institutions and between central and local governments. China has strengthened its enforcement of the laws and regulations on biodiversity and improved its monitoring and observation networks (State Council Information Office of the People’s Republic of China 2021). China’s NBSAP (2023–2030) emphasizes this point by requiring local governments to mainstream biodiversity considerations into five-year plans and establishing a biodiversity conservation system dominated by the government and participated by non-state actors. Several provinces have released their own NBSAPs and regulations on biodiversity (Gu et al. 2025). However, more efforts are needed (Hu et al. 2023). For instance, the details of the monitoring and review procedures are not stipulated in legislation. Moreover, considering the whole-of-government and whole-of-society approach as requested by the GBF, the roles of local governments and the coordination between the central and local governments in promoting the realization of GBF and national targets should be emphasized. However, China’s local governments have not yet fully incorporated the GBF targets and national targets into their regulations (Gu et al. 2025). Thus, local governments should be mobilized to set targets on biodiversity conservation, monitoring the progress of solving biodiversity issues, and implement legal measures as stipulated in the laws and regulations on biodiversity. Lastly, the progress of the implementation should be publicized to raise the public’s awareness of biodiversity conservation and incentivize the relevant actors to take substantive measures to conserve and restore biodiversity.

4.2. The EU

The EU takes a nature-positive approach and promotes ecosystem services that are demanded by the GBF (Carroll et al. 2022). As shown above in Section 3.2, the EU biodiversity law covers the three levels of biodiversity as defined by the CBD, i.e., ecosystems, species, and genetic resources (Carroll et al. 2022; de Sadeleer 2017). Article 191(1) of the TFEU provides a treaty basis for the EU translating the GBF targets into national targets at the EU level. The Nature Directives, the NRL, the Invasive Alien Species Regulation, and the ABS Regulation are typical examples of legislation in the EU. In addition, the preventive and remedial measures provided for in the Environmental Liability Directive (Directive 2004/35/CE) can be applied to situations where there is a serious adverse impact on the ecological environment due to the destruction of habitats, species, and water resources. It serves to protect biodiversity from the perspective of preventing environmental damage and providing relief.

Similarly to China, the EU does not have a special biodiversity law (de Sadeleer 2017). Although the Nature Directives generally stipulate measures regarding the protection and restoration of biodiversity and the NRL stipulates restoration measures, they cannot serve as comprehensive and special laws on biodiversity. The Nature Directives mainly focus on the protection of certain species and habitats. The NRL consists of six chapters, which, respectively, stipulate general principles, restoration targets and obligations, national restoration plans, monitoring and reporting, delegated and implementing acts, and final provisions. Previously, requirements related to nature restoration were scattered across directives, including the Nature Directives, the Water Framework Directive (Directive 2000/60/EC), the Marine Strategy Framework Directive (Directive 2008/56/EC), and the Regulation (EU) 2018/841 on Emissions and Removals from Land Use, Land-use Change and Forestry. The NRL takes the form of a regulation rather than a directive and will be directly applicable in member states, which to a certain extent solves the problem of the lack of system and coordination of existing laws and regulations related to nature restoration (da Silva 2023). The NRL adopts a holistic perspective on biodiversity restoration, encompassing various types of degraded ecosystems across the continent (Hoek 2022; Perissi 2025; Prach et al. 2025; Sowery 2024; Stoffers et al. 2024). Moreover, the NRL takes the form of a regulation rather than a directive and will be directly applicable in member states, which, to a certain extent, solves the problem of the lack of a system and the coordination of existing laws and regulations related to nature restoration (da Silva 2023). However, the NRL is deemed as ‘additional’ to current directives and regulations on restoration of biodiversity and cannot cover all measures that reverse biodiversity loss. A framework directive on biodiversity is thus needed to specifically provide for the general objectives and legal measures that implement the GBF.

As with China, the EU also faces implementation problems with environmental laws, including those concerning biodiversity (Carroll et al. 2022; de Sadeleer 2017; Gehring et al. 2019; da Silva 2023). The multilevel cooperation, especially between the EU and its member states is important for biodiversity conservation (Wang 2023). Although the EU environmental law is ultimately implemented by the member states, the EU takes a lead in ensuring the effective operationalization of environmental law, with support of the courts of the EU (Gehring et al. 2019). The European Commission reviewed the implementation progress of the EU 2030 Strategy during the mid-term evaluation of the 8th Environmental Action Plan. The basic conclusion is that there has been some progress in implementation. However, many strategic goals, such as the 30 by 30 conservation target, still require more efforts from all parties (The European Commission 2024). To achieve the expected goals of the EU Biodiversity Strategy for 2030, the EU needs to improve the coordinated actions of member states, provide sufficient financial support, mainstream biodiversity, and encourage public participation (Hermoso et al. 2022). These actions are also key to implementing the NRL (Hering et al. 2023).

Focusing on the monitoring and review of the implementation of the national targets of the EU, at least the following three approaches have been taken: First, the EU and the UN Environment Programme World Conservation Monitoring Centre (UNEP-WCMC) have promoted the establishment of the Global Knowledge Support Service for Biodiversity to provide data and technical support to countries in need and help monitor their progress in achieving the GBF. Furthermore, to coordinate biodiversity monitoring activities within Europe and establish an EU biodiversity monitoring network, the EU is building the European Biodiversity Observation Coordination Centre (EBOCC). This centre will enhance the level of EU biodiversity monitoring by coordinating monitoring activities, collecting and sharing monitoring data, and improving monitoring capabilities (Liquete et al. 2024).

Second, the EU proposed to adopt laws on monitoring biodiversity. The draft Soil Monitoring Law (COM(2023)416) adopted by the European Commission in July 2023 is based on the EU Soil Strategy for 2030 and aims to encourage member states to establish soil quality standards, collect and summarize data on soil health, and promote the EU’s achievement of the goal of having healthy soil by 2050. This can facilitate the achievement of GBF targets 1 and 7. The draft Forest Monitoring Law (COM(2023)728) adopted by the European Commission in November 2023 is based on the New EU Forest Strategy for 2030. It aims to establish a forest monitoring framework to collect and share forest data so that member states, forest owners, and forest managers can deal with problems such as wildfires and illegal logging promptly and enhance the resilience of forests. This can facilitate the achievement of GBF target 1.

Third, the EU has established platforms to disclose information on the implementation of its national targets. The EU established the Knowledge Center for Biodiversity (KCBD), the EU Biodiversity Platform, and the Biodiversity Information System for Europe (Viti et al. 2024). Among them, the KCBD developed the EU Biodiversity Strategy Actions Tracker (2025) and the EU Biodiversity Strategy Dashboard (2025) to track the progress of the EU in implementing more than 100 specific targets of the EU Biodiversity Strategy for 2030 and present them to the public. As of September 2025, 51 of the more than 100 action targets have been completed, 44 are in progress, and 9 have been delayed.

4.3. Analysis

Both China and the EU have established legal frameworks and measures to protect biodiversity. These legal frameworks and measures serve as the basis for China and the EU to fulfil the goals and targets of the GBF. As clearly admitted by their NBSAPs, the biodiversity laws in China and the EU require further improvement. Therefore, in addition to promoting the implementation of the GBF at the international level, China and the EU are enacting or revising their domestic biodiversity laws, respectively. China is drafting an environmental code that will codify the general objectives, legal principles, and measures for biodiversity conservation and restoration. The EU has adopted the NRL to regulate nature restoration comprehensively. However, as shown in

Table 2. China and the EU’s legal frameworks and support measures that promote the achievement of the GBF targets.

Dimensions		China	The EU
Legal frameworks	A special law on biodiversity	None	None
	Coverage of all three objectives of the CBD	Partially covered	Covered
	Measures to improve	The draft environmental code	Enacting or revising legislative acts for specific GBF targets
Monitoring and review mechanisms	Monitoring networks	Being built	Being built
	Monitoring laws	Not enacted	Being enacted
	Involvement of local governments and non-state actors	Local governments being mobilized	Progress of implementing national targets being publicized

above, in both China and the EU, further efforts are needed if the aims of their NBSAPs and the GBF targets are to be fully realized.

China’s legal framework on biodiversity needs to be carefully designed, even after the environmental code is adopted. As explained above, compared with the EU, there is a lack of specific laws and regulations that facilitate the achievement of certain GBF targets, such as targets 8 and 13. The EU’s experiences in establishing legal provisions that promote the synergetic governance of biodiversity and climate change and regulate the utilization and benefit sharing of genetic resources can be referenced by China. Furthermore, the EU’s emphasis on the effective implementation of domestic policies and laws regarding biodiversity, as well as the development of support measures, may also have implications for China.

Regarding the EU’s legal framework on biodiversity, one often-mentioned point is that a comprehensive biodiversity law is absent, demanding the EU to take a holistic approach to addressing biodiversity loss (de Sadeleer 2017; Kramer 2016; da Silva 2023). The Nature Directives stipulate measures for the protection of species and habitats. However, it cannot function as a comprehensively special law on biodiversity. The adoption of the NRL, to an extent, overcomes the weaknesses of previous biodiversity laws, as it connects or is supported by current directives, strategies, and other policy documents and will also promote the implementation of other legislation and policies (de Leeuw and Backes 2024; Hering et al. 2023; Sowery 2024). China’s enactment of the environmental code paves the way to restructure its legal frameworks and measures on biodiversity. The holistic systems view used for designing and implementing biodiversity conservation measures may have implications for the EU regarding the streamlining of its biodiversity laws.

5. Conclusions

The achievement of the goals and targets of the GBF relies on the effective national implementation by multilevel actors. Common challenges exist for the parties to the CBD, including aligning national targets with the GBF targets; translating policy commitments into legally binding obligations; establishing systematic legal frameworks and measures for biodiversity conservation and restoration; and, lastly, effectively implementing relevant legal measures. China and the EU are among the parties that have actively implemented the CBD and GBF. They have submitted their NBSAPs and national targets as requested by the Secretariat of the CBD and have continued to restructure the legal frameworks and streamline legal measures to promote the achievement of the goals and targets of the GBF. China and the EU can be mutually inspired by each other on how to better implement the GBF. Meanwhile, their legal approaches towards translating the GBF targets and implementing the national laws and regulations on biodiversity conservation will offer insights to the other parties to the CBD. On the one hand, China may learn from the EU’s approach to incorporating national targets into legislation by enacting specific laws and regulations that directly aim to implement certain GBF targets. The EU’s emphasis on implementation and the development of support measures may also have implications for China. The EU is more advanced at setting legal criteria and procedures to establish a scientific knowledge basis for biodiversity monitoring and publicizing progress toward meeting national targets on biodiversity conservation. The adoption of the NRL and the development of monitoring and review mechanisms for tracking progress in GBF implementation are examples. On the other hand, China’s draft environmental code adopts a holistic perspective on biodiversity conservation and restoration, which may inspire the EU to establish specific and systematic legal frameworks and measures for biodiversity. Moreover, China excels in mobilizing local governments to set local-level targets and help establish national-wide biodiversity monitoring networks. China’s centralized governance system on biodiversity and its mechanisms to coordinate the central and local governments may also offer insights for the EU in coordinating actions among its member states. However, it should be noted that certain limitations warrant further analysis. For example, innovative policy instruments require in-depth study; factors influencing the enforcement of biodiversity laws may not be fully addressed due to space constraints; and the potential of biodiversity litigation to strengthen the effective implementation of the GBF is not emphasized here. Furthermore, the comparative analysis of how China and the EU are translating the GBF into law yields several insights for the other parties to the CBD. Primarily, it is crucial that the parties achieve not only a high alignment of national targets with the GBF but also their thorough integration into legal texts, including through overarching clauses that codify commitments to MEAs and biodiversity conservation. Moreover, the GBF, with its progressive requirements, should be leveraged as a catalyst for comprehensively improving domestic biodiversity legislation. Finally, the success of implementation hinges on the active mobilization of all levels of state and non-state actors and the establishment of effective monitoring and review frameworks.