An urban underground logistics system (ULS) is one important means of solving urban traffic problems that has unique advantages. Freight transportation in China requires a new transportation mode. Therefore, ULS has garnered increasing attention. However, to date, few scholars and practitioners have investigated ULS in China. Although ULS shows good development opportunities, it also faces great challenges. Based on the Macro-environment and situation analysis (PEST-SWOT) model, which is a strategic analysis method that combines both SWOT and PEST to effectively identify advantages, disadvantages, opportunities and threats, this paper first uses PEST to analyze the macro-environment of ULS in China and identify its internal factors (i.e., advantages and disadvantages) and external factors (i.e., opportunities and threats). Next, based on the SWOT framework, this paper proposes several development strategies and recommendations that provide a comprehensive and novel perspective to the study of ULS in China.