Abstract: The Energy Law plays an important role in energy transition of China. Yet China’s Energy Law has undergone three legislative drafts and four legislative agenda initiations without being passed into law. Why has the Energy Law been in legislative gridlock? This paper explores this issue from an external legal perspective, utilizing the theory of punctuated equilibrium to analyze the dynamic legislative process of China’s Energy Law. It finds that with legislators’ understanding of the Energy Law evolving, the legislative process encountered three gridlocks centered around balancing the trilemma of energy security, low-carbon energy, and energy justice. While focal events provided structural opportunities to initiate the Energy Law, legislative disagreements and shifts in legislative attention led to gridlocks in the agenda. Nevertheless, urgent legislative needs and attention from decision-makers have allowed the legislative agenda to restart. Under the guidance of the punctuated equilibrium theory, the following explorations should be undertaken for the formulation of China’s Energy Law. First, in terms of determining legislative concepts, it is essential to integrate domestic and international energy situations and the background of energy legislation, seize opportunities for energy legislation, and accelerate the legislation of the Energy Law with a focus on energy security. Second, regarding the choice of legislative model, it should be clarified that the Energy Law serves as a fundamental law, coordinating its conflicts and connections with specific energy laws, building consensus to reduce legislative resistance, and focusing attention on expediting legislation. Third, concerning the design of legislative institutions, it should sequentially and categorically address the trilemma of energy issues, meeting legislative needs, achieving the legalization of top-level designs set by decision-makers, and fulfilling public expectations to effectively resolve the legislative gridlock of the Energy Law.