This article examines the process of China's borrowing of the Japanese vocational education model from 1895 to 1922 from the perspective of educational policy transfer. This study serves as a unique example in educational policy transfer research where historical sources offer the possibility of testing the applicability of the Contextual Map of Cross-national Attraction model. It elucidates some of the analytical limitations discovered by this study while applying the model to this study. It implies that more theory, particularly on the issue of the complex interaction between structure and agency, about the nature of educational policy transfer is needed to comprehensively and sophisticatedly analyse the complex process of educational transfer.