随着经济全球化的发展,贸易保护主义的滋生,竞争愈演愈烈,各国着眼世界竞争发展形势,致力于保护本国贸易,完善本国竞争法制。中国更是顺应经济发展潮流,努力建立与完善竞争法制,这对中国而言,是一大难题和挑战。本文在与德国和美国竞争法作比较的视角下,研究中国应如何建立和完善本国的竞争法制。 With the development of economic globalization and the emergence of trade protectionism, competition has become more and more intensified. All countries focus on the situation of world competition and development and are committed to protecting their own trade and improving their own competition law. In conformity with the trend of economic development, China is also striving to establish and improve the competition law system. This is a big challenge and challenge for China. This article studies how China should establish and improve its own competition law system from the perspective of competition law between Germany and the United States.