To help overcome the challenge of growing CO2 emissions, China is experimenting with market-based instruments, including pilot CO2 emissions trading systems (ETSs) in seven regions that serve as precursors of a national CO2 ETS. Implementing an ETS in a rapidly growing economy in which government authorities exercise significant control over markets poses many challenges. This study assesses how well three of the most developed pilot ETSs, in Guangdong, Shanghai, and Shenzhen, have adapted carbon emissions trading to China's economic and political context. We base our study on new information gathered through interviews with local pilot ETS regulators and experts, analysis of recent trading data, and extensive legal and literature reviews. We point out instances in which pilot regulators have deftly tailored carbon emissions trading to China's unique context and instances in which designs are insufficient to ensure smooth operation. We also indicate areas in which broader institutional reforms of China's political economy may be required for carbon emissions trading to operate successfully. We make nine recommendations to improve the design and operation of the pilot programs and to inform the construction of a national CO2 ETS. (C) 2016 Elsevier Ltd. All rights reserved.