The TCM trade in services involves many entities, and the service content is varied, making TCM trade in services complex. A clear understanding of its complexity is a prerequisite to manage and motivate them, and to promote their rapid, orderly and sustainable development. Firstly, the entities of TCM trade in services are classified and described in general terms. Then, this paper analyses the constitutional complexity, behavioral complexity, relational complexity and model complexity of TCM trade in services. On this basis, the essay explores the existing problems of TCM trade in services, and puts forward corresponding countermeasures and suggestions.