The controversy over whether environmental criminal law is administratively subordinate is related to the value positioning and function realization of environmental criminal law,and its resolution is a due responsibility for the theoretical development of environmental criminal law.From a practical point of view,environmental crimes are regarded as statutory crimes.But even if it is a legal offense,administrative subordination cannot be generalized,the illegality of each sectoral law is relative,environ-mental criminal law is not absolutely subordinate to the environmental administrative law.Overview of the development of envi-ronmental criminal law benefit concept trajectory,ecological interests have an important value,environmental criminal law of absolute administrative subordination is not in line with the ecological anthropocentric benefit concept,environmental adminis-trative intervention and environmental criminal intervention has the essential difference.From the contingent level,the bounda-ries between natural and legal offenses will change in social life.With the development of ecological civilization,environmental crimes show a development towards the natural offender direction.In this process,the administrative subordination of environ-mental criminal law has been weakening or even completely detached.Maintaining the independence of environmental criminal law can maximize the ultimate goal of protecting the overall ecological and environmental legal benefits.