Three kinds of emulsifying agents were used as emulsion droplet to prepare particle/emulsion complexes ERF in order to explore the infection of emulsifying agents on rheological properties. The rheological properties and microstructure of such ERFs were examined, the model of complex chain for particle/emulsion complexes ERF was given. Using emulsifying agents is the efficient way to improve the ER effect in dry-based ERFs. There are three manners for the emulsifying agents in EFRs, those are coating on the surface of particle, dissolving in continued phase and distributing in continued phase as droplets, which was determined by the interaction among particle, emulsifying agents and the oil. For higher polarity emulsifying agent, the complexes particles aggregate to form bulk and can't disperse in oil. For moderate one, the complexes particles dispersed in oil and formed complexes chains or columns, the neighboring complex chain form network structure due to the rotation of complex particle display stronger EF effect. Lower polarity emulsifying agent dissolved in silicone oil, the ERF showed lower electrorheological properties due to the decreasing of the mismatch of conductivity between particles and continue phase.