This study presents some of the current methodological issues regarding the analysis and comprehension of educational policy transfer, with particular emphasis on the issue of structure and agency. It suggests some shortcomings of current educational policy transfer research in dealing with the complex interaction between structure and agency. To fill those voids, drawing from Archer's morphogenetic approach in educational policy transfer, an alternative framework of educational policy transfer is presented. A case from the author's current research on China's interest in Japanese vocational education during the late Qing Dynasty is given to explain the usage of this new interpretive framework. It is hoped that this new conceptual framework will aid in analysing educational policy transfer and open up a new methodological and theoretical space for future educational policy transfer research.