The agenda for improving China’s building energy efficiency is not progressing smoothly, mainly due to many risks associated in the China’s building energy efficiency market mechanism. This paper employs a system dynamics methodology to analyse these risks, by dividing the risks in the building energy efficiency market into six subsystems: laws and regulations; standards and specifications; economy; technology; policy and education. The paper further analyses the relationship between these subsystems and their relationships with the overall system (building energy efficiency market) by establishing and drawing the causal relationships and feedback loops. Through a qualitative analysis on the positive and negative feedback loops of the system, potential risks were ascertained, and new perspectives established for the implementation and monitoring of risk tackling strategies. It is expected that the results presented in this paper will help decision makers to identify the risk factors and their interdependent relationship in a complex context system involving law, economy, policy, market, education and technology issues.