Abstract: he popularization of Internet has created convenience for the dissemination of hate speech and brought about certain negative social effects particularly within the EU. Due to the differences in history and culture of different countries, there are also great differences in the understanding and governance of hate speech in the international community. EU countries advocate combating the spread of hate speech in legal form, but the United States does not accept the concept. Meanwhile, the impact of regulatory activities on freedom of expression is also difficult to assess. Thats the reason why its difficult to control hate speech in the international area. Based on the international communitys understanding and governance practice of hate speech, this paper puts forward the constitutive factors of hate speech as a criterion. Then combining the practice of governing hate speech on overseas Internet platforms and in the EU region, this paper analyzes the specific situation of governing hate speech in China.

Key words: Internet hate speech, concept, identifying, Internet governance, international governance

摘要： 网络普及为仇恨言论传播创造了便利，也带来了一定的社会负面影响，尤其是在欧盟国家. 由于各国历史、文化间的差异，国际社会对仇恨言论的认识和治理也存在非常大的差异性. 欧盟国家主张以法律形式规范、打击仇恨言论传播，而美国则不认同仇恨言论，相关规制活动对言论自由的影响也难以评估，实质造成了国际范围内打击网络仇恨言论的困难. 基于国际社会对仇恨言论的理解认识及治理实践，提出将仇恨言论构成因素作为判别条件，通过结合在互联网平台和欧盟地区的治理实践，分析了国内治理仇恨言论的特殊情况.

关键词: 网络仇恨言论, 概念, 判别, 网络治理, 国际治理