Working within the RECREATE project1, partly funded by the EU, the researchers identified five main differences in the way farmland is converted for development in these three countries:
1. Ownership of land property. Farmland in Germany and the Netherlands is privately owned. Owners must seek permission from the relevant authorities to change the use of the land for building purposes, which is granted if the scheme fits in with local land use and construction plans. In China, farmland is collectively owned and farmers are granted farming rights from village committees. Although these rights can be transferred to other villagers or rented to outsiders, the land can only be used for agricultural purposes.
Full compensation, including increased value of the land after development, is paid to owners in the Netherlands and Germany for compulsory purchase of farmland. Uncertain ownership of the land in China results in comparatively lower amounts paid in compensation. In addition, while farmland owners can appeal to independent courts in European countries, there is a lack of property protection through an independent court in China.
2. Land use planning. There are differences in the land use planning systems' aims. The Netherlands and Germany focus on balancing human and environmental needs, enhancing the rural-urban balance and making decentralised governance more efficient. In addition to these goals, China also focuses on controlling rapid farmland loss.
China's top-down system allocates quotas to local governments, which can lead to mismatches between demand for land conversion and quotas allocated. In Germany and the Netherlands, local governments design and implement the priorities set by national and provincial authorities. Public participation by all stakeholders in the design, approval and implementation of land use planning in Germany and the Netherlands can be missing in China.
3. The role of the market. The Chinese government mainly controls land assessment. In Germany and the Netherlands, however, there is a system of transparent land assessment by public or private bodies, as well as free market competition.
4. The role of government. In China, the government controls all stages of converting farmland. This contrasts with both the Netherlands and Germany, where governments cooperate with the private sector in land development. Any profits from farmland conversion in China are mostly collected by the government and contribute towards the country's economic growth, whereas farmers are paid some compensation by the German and Dutch governments.
5. Performance of governance structures on farmland conversion. Different economic and social conditions affect land supply and demand in all three countries making direct comparisons difficult. However, the study made broad comparisons in how the governments minimise costs, achieve more efficient use of resources and improve welfare distribution of the profits from land development projects.