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Abstract Elaborating on the analytical framework of governance, this paper discusses three aspects of governance including the approach of how NGOs achieve subject legitimacy in environmental-governance participation, the legalization of participatory approaches, and the effectiveness of participatory result. The author takes the revision process of the Chinese Environmental Protection Law as a case study for thick description. It shows that ‘practice of self-identification’ is an effective approach for NGOs to construct subject legitimacy as they participate in environmental or even national governance, and the practice field with participation of multi acting subjects has already been and will continue to be a space to test for ‘good governance’ in China.