Platform Recommender Systems (PRSs) are the algorithmic systems employed by online platforms to recommend content to users. These systems have been recently targeted by policy-makers in Europe, mainly in the Digital Services Act (DSA). While much is discussed on the merits and limitations of the DSA, the very first world regulation of PRSs has been implemented by the People’s Republic of China since March 1st 2022. The article elaborates a critical comparative analysis of the governance of PRSs between the Chinese and European regulations. By contextualizing the highly diverse media environments, the article bridges the gaps between legal, technical and social sciences disciplines to elaborate insights that aim to contribute to the development of the governance of PRS. The article is divided as follows; firstly, an introduction to the governance of platforms RSs is done. Then, a contextualization of European and the Chinese legal and media environment is provided. Secondly, a legal comparative analysis is developed by analyzing two main areas: algorithmic accountability and self-determination. Thirdly, a discussion on the challenges of PRS governance is elaborated and, eventually, conclusions are drawn. From the comparison we have identified fundamental challenges and opportunities for the development of PRSs governance: (1) the methodological validity of social media research and the possibility to run on-platform experiments for more sounding policies; (2) the inherent reductionism of profiling and the need to tackle the implicit “engagement optimization” paradigm; (3) the systemic vulnerability of users and the need to improve detection, prevention and legal codification of algorithmic and design manipulation; (4) the complex entanglement of PRS governance with interface design, content moderation and content visibility moderation; finally, (5) the promising role of users to provide a second-order accountability as well as strenghten individual self-determination through forms of participatory governance.