English, or “Bad English,” as my university foreign affairs colleague quips, “is the new global language.” Chinese students take English very seriously, posing puzzles with predictable unexpectedness. “Professor Dan,” a student asks, “in Brown v Board of Education, we learn that ‘separate but equal’ is a bad thing, but the Declaration of Independence says that the United States should be ‘separate and equal.’ How can this be?” Where does an answer begin (and how many of my Yale Law classmates recall the phrase “separate and equal” in the Declaration)?

To teach law and government in China is to traffic in the global vernacular of governance – a key western export. Governance is the late 20th-century western notion that the state is necessary but not sufficient to the performance of basic public purposes; new mixes of governmental and nongovernmental institutions are needed. China has determinedly joined America as a practitioner of pragmatism, drawing from global experience to make things work. The new global vernacular of governance – featuring terms like “transparency,” “accountability,” “NGOs” and “market measures” – is at work in classrooms and conferences in Beijing.

But the new lingua franca flourishes independent of any common understanding of what words actually mean in divergent local settings. As China mixes markets and socialism, comparison and translation become both increasingly plausible and perhaps increasingly elusive.

Take, for example, “Rule of Law” – a cornerstone of western creed, and a key export to China and the developing world. A visitor finds the term readily accepted, even officially embraced. Activities that pursue the “Rule of law” are OK. But what does it mean? Newcomers are told the Chinese term (“fa zhi”) is fundamentally ambivalent – it could mean the tool the ruler uses to assure his sway, or a means to bind and limit the ruler. The western export is equally ambivalent.

For me, the primary alternatives include rules that define and limit the authority of government, and rules that protect property. Perusing a just-issued compendium on the subject, one finds that these two meanings are just starters; further alternatives include no meaning at all, and use as a code word – concepts less directly discussable.

Differing traditions make translation even more daunting. Americans, who view the rule of law through the common law lens (featuring a prominent role for courts that are independent and make law), may be hard pressed to distinguish the absence of the rule of law from the presence of civil law derived from “Old Europe.” American governance is premised on a tradition in which competition among “civil society” interest groups (“factions”) is vice, virtue and key to social stability. In China, governance discussions focus on making government work better; NGOs, at least at present, emerge as government-sponsored aids to shorthanded government.

Americans may see government-sponsored NGOs as a contradiction in terms. Even so, Chinese students seeking to understand the American system highlight tensions in American governance that bear reflection; e.g., how is it that private interests can represent the public interest – isn’t this what government is for? And how do we know which private interests represent the public interest? Americans have not so much answered such questions, but, through long and ongoing “conversation” among courts, citizens and executive branch, venerate the idea of private assertion of the public interest, notwithstanding simultaneous awareness that one man’s public interest may be another’s special interest.

Governance critically involves informal, as well as formal, laws or rules. Here, also, comparison is suggestive but elusive. China is said to be characterized by guanxi – relationships that make the world work, but also may be means for corruption. How to compare and contrast guanxi to American lobbying, schmoozing and networking? The book remains to be written.

Similarly, the terms of central/local relations, critical to environmental governance, invite comparison. American Federalism is rooted in constitutionally defined principles of dual sovereignty, but has been famously characterized as a marble, not a layer, cake. China lacks constitutional dual sovereignty, and party officials are present at all levels; still, the view that local governments exercise considerable practical autonomy is omnipresent, and said to be rooted in millennia of tradition.

In China and America, governance thinking is shaped by debate on “win-win” solutions to problems of economy vs. environment (including the view that the debate is miscast). Here, the broad terms of debate may seem similar, but the particulars render translation difficult. Americans, as historian David Potter put it, are a “people of plenty.” China, its continuing remarkable economic achievements notwithstanding, remains a developing country.

In sum, as China develops, the English language global governance vernacular will inevitably be used to track the change, but the language must be used with care. Attention to the practical meanings of common terms in China and America should enrich the growing global vernacular of governance and its practical utility in both countries.

So my contribution to the next Lonely Planet guide is to suggest that the challenge for the tourist in China today lies not only in the classic highlights of Chinese civilization and culture – be they the man-made or natural. These highlights, however hard for the outsider to absorb, are at least well signposted. Rather, the challenge, as China rises in the globalized world, may lie in the old that may be disarmingly embedded in the familiar and therefore unsignposted – including the global vernacular of English itself.

Dan Guttman is a Fulbright scholar teaching at Shanghai Jiao Tong, Tsinghua and Beijing universities. In the United States, he teaches at Johns Hopkins University and is a practicing attorney in Washington, D.C. He wrote this piece in conjunction with the Camden Conference, “China on the World Stage,” scheduled for Feb 24-26.