在现代社会中,环境侵权数量正在日趋增加。而在我国,环境侵权作为一种新型的侵权行为,对其规制尚存在许多的不完善之处。要对环境侵权进行规制,首先要准确定义环境侵权之概念,最行之有效的方法是比较分析各国相关概念,而德国法和英美法作为现代西方两大法系之典型代表,应为比较研究之重点。 In modern society, the number of environmental violations is increasing. In China, environmental infringement as a new type of tort, there are still many imperfections in its regulation. To regulate environmental infringement, we must first accurately define the concept of environmental infringement. The most effective way is to compare and analyze the relevant concepts in different countries. German law and Anglo-American law, as typical representatives of the two major legal systems in the modern West, should be comparatively studied Focus.