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United States securities and exchange commission logo

                               December 12, 2022

       Zhu Youyi
       Chief Financial Officer
       China Natural Resources, Inc.
       Room 2205, 22/F, West Tower, Shun Tak Centre
       168-200 Connaught Road Central
       Sheung Wan, Hong Kong

                                                        Re: China Natural
Resources, Inc.
                                                            Registration
Statement on Form F-3
                                                            Filed November 18,
2022
                                                            File No. 333-268454

       Dear Zhu Youyi:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments. In some of our comments, we may ask you to
provide us with
       information so we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-3 filed November 18, 2022

       Cover Page

   1.                                                   We note your disclosure
that the PCAOB has yet to determine that it may inspect your
                                                        auditor in relation to
its audit work to its satisfaction, and that your common shares will be
                                                        prohibited from trading
in the United States under the HFCAA in 2024 if the PCAOB is
                                                        unable to inspect or
fully investigate auditors located in China, or in 2023 if proposed
                                                        changes to the HFCAA
are enacted. Please disclose here, if true, that your auditor is
                                                        subject to the
determinations announced by the PCAOB on December 16, 2021. Please
                                                        make similar revisions
to your disclosure regarding same in your prospectus summary, at
                                                        page 6, and your risk
factor summary, at page 7.
 Zhu Youyi
FirstName LastNameZhu
China Natural Resources, Youyi
                         Inc.
Comapany12,
December  NameChina
              2022    Natural Resources, Inc.
December
Page 2    12, 2022 Page 2
FirstName LastName
2.       Please update your disclosure regarding the Statement of Protocol here
and elsewhere to
         reflect that the PCAOB will be required to assess its determinations
regarding inspections
         by the end of 2022.
3.       Please revise to identify clearly here and in your prospectus summary
the entity (including
         the domicile) in which investors are purchasing an interest.
4.       We note your disclosure regarding transfers of cash and assets between
you and your
         subsidiaries. Please expand your disclosure to discuss whether any
transfers, dividends or
         distributions have been made to investors and quantify the amounts
where applicable.
5.       Please clarify that all of the legal and operational risks associated
with having operations
         in the PRC also apply to operations in Hong Kong and Macau.
Prospectus Summary, page 3

6.       We note your disclosure in the first paragraph of page 3. Please
expand your summary of
         risk factors to disclose or discuss in greater detail the risk that
your corporate structure and
         being based in or having the majority of the company   s operations in
China poses to
         investors. In particular, describe the significant regulatory,
liquidity, and enforcement
         risks with cross-references to the more detailed discussion of these
risks in the prospectus.
         For example, specifically discuss risks arising from the legal system
in China, including
         risks and uncertainties regarding the enforcement of laws and that
rules and regulations in
         China can change quickly with little advance notice; and the risk that
the Chinese
         government may intervene or influence your operations at any time, or
may exert more
         control over offerings conducted overseas and/or foreign investment in
China-based
         issuers, which could result in a material change in your operations
and/or the value of the
         securities you are registering for sale. Acknowledge any risks that
any actions by the
         Chinese government to exert more oversight and control over offerings
that are conducted
         overseas and/or foreign investment in China-based issuers could
significantly limit or
         completely hinder your ability to offer or continue to offer
securities to investors and
         cause the value of such securities to significantly decline or be
worthless.
Risk Factors
Uncertainties with respect to the PRC legal system could adversely affect us.,
page 9

7.       Given the Chinese government   s significant oversight and discretion
over the conduct of
         your business, please revise to highlight separately the risk that the
Chinese government
         may intervene or influence your operations at any time, which could
result in a material
         change in your operations and/or the value of the securities you are
registering.
ENFORCEABILITY OF CIVIL LIABILITIES, page 43

8.       We note your disclosure that all of your assets and all of your
directors and officers are
         located outside the United States. Please revise to clarify those of
your officers and
         directors who are located in the PRC, and those that are located in
Hong Kong, if any.
 Zhu Youyi
China Natural Resources, Inc.
December 12, 2022
Page 3
General

9.    Please confirm your understanding that we will not be in a position to
accelerate the
      effectiveness of your registration statement until our comments relating
to your Form 20-F
      for the fiscal year ended December 31, 2021 have been resolved.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Liz Packebusch, Staff Attorney, at (202) 551-8749 or
Karina Dorin,
Staff Attorney, at (202) 551-3763 with any other questions.

                                                           Sincerely,
FirstName LastNameZhu Youyi
                                                           Division of
Corporation Finance
Comapany NameChina Natural Resources, Inc.
                                                           Office of Energy &
Transportation
December 12, 2022 Page 3
cc:       Leland S. Benton
FirstName LastName
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