SEC Company Response from CHINA NATURAL RESOURCES (CHNR) — Oct 6, 2025
CHINA NATURAL RESOURCES INC
Date: Oct. 6, 2025 · CIK: 0000793628 · Accession: 0001079973-25-001558
AI Filing Summary & Sentiment
File numbers found in text: 000-26046
Referenced dates: April 8, 2025, August 7, 2025
Letter
VIA EDGAR Division of Corporation Finance Office of Energy & Transportation Securities and Exchange Commission Re: China Natural Resources, Inc. Form 20-F for the Fiscal Year Ended December 31, 2024 Filed May 15, 2025 File No. 000-26046
Dear Mr. McAllister and Ms. Buskirk,
This letter sets forth the Company’s responses to the comments contained in the letter dated August 7, 2025 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s Form 20-F for the fiscal year ended December 31, 2024 filed with the Commission on May 15, 2025 (the “2024 Form 20-F”). The Staff’s comments are repeated below in bold and are followed by the Company’s responses thereto. All capitalized terms used but not defined in this letter shall have the meaning ascribed to such terms in the 2024 Form 20-F.
Form 20-F for the fiscal year ended December 31, 2024
Item 16F. Changes in Registrant's Certifying Accountant, page
1. You disclose that a copy of EY’s letter dated April 8, 2025, is attached as Exhibit 16.1. Please amend and file the former accountant’s letter as an exhibit to your annual report.
Response: The Company acknowledges the Staff’s comment and respectfully file the former accountant’s letter as Exhibit 16.1 to the 2024 Form 20-F/A.
Appendix A Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
2. Please amend to have your auditors revise the first paragraph of their report to include the consolidated statement of profit or loss when they identify each financial statement and schedule that has been audited, as required by PCAOB Auditing Standard (AS) 3101.08.b. Also revise the second paragraph to disclose that all these factors raise “substantial doubt” about the company’s ability to continue as a going concern, as required by paragraph 18.a. of the Auditing Standard. You may also refer to PCAOB AS 2415.12 through 2415.13.
Response: The Company acknowledges the Staff’s comment and respectfully revised the audit report accordingly.
* * * *
If you have any additional questions or comments regarding the 2024 Form 20-F, please contact the undersigned at +86 10 8551 1066 or the Company’s U.S. counsel, Richard Chang of Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP at +86 10 5680 3969 or rchang@gunder.com.
Very truly yours,
/s/ Zhu Youyi
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CORRESP
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VIA EDGAR
October 6, 2025
Mr. Brian McAllister
Ms. Shannon Buskirk
Division of Corporation Finance
Office of Energy & Transportation
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: China Natural Resources, Inc.
Form 20-F for the Fiscal Year Ended December 31, 2024
Filed May 15, 2025
File No. 000-26046
Dear Mr. McAllister and Ms. Buskirk,
This letter sets forth the Company’s responses
to the comments contained in the letter dated August 7, 2025 from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) regarding the Company’s Form 20-F for the fiscal year ended December 31, 2024 filed
with the Commission on May 15, 2025 (the “2024 Form 20-F”). The Staff’s comments are repeated below in bold and
are followed by the Company’s responses thereto. All capitalized terms used but not defined in this letter shall have the meaning
ascribed to such terms in the 2024 Form 20-F.
Form 20-F for the fiscal year ended December 31, 2024
Item 16F. Changes in Registrant's Certifying Accountant, page
78
1. You disclose that a copy of EY’s letter dated April 8, 2025, is attached as Exhibit 16.1. Please amend and file the former
accountant’s letter as an exhibit to your annual report.
Response: The Company acknowledges the Staff’s comment and respectfully
file the former accountant’s letter as Exhibit 16.1 to the 2024 Form 20-F/A.
Appendix A Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page
F-2
2. Please amend to have your auditors revise the first paragraph of their report to include the consolidated statement of profit or
loss when they identify each financial statement and schedule that has been audited, as required by PCAOB Auditing Standard (AS) 3101.08.b.
Also revise the second paragraph to disclose that all these factors raise “substantial doubt” about the company’s ability
to continue as a going concern, as required by paragraph 18.a. of the Auditing Standard. You may also refer to PCAOB AS 2415.12 through
2415.13.
Response: The Company acknowledges the Staff’s comment and respectfully
revised the audit report accordingly.
* * * *
If you have any additional questions or comments
regarding the 2024 Form 20-F, please contact the undersigned at +86 10 8551 1066 or the Company’s U.S. counsel, Richard Chang of
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP at +86 10 5680 3969 or rchang@gunder.com.
Very truly yours,
/s/ Zhu Youyi
Zhu Youyi
Chief Financial Officer
cc: Richard Chang, Esq., Partner, Gunderson
Dettmer Stough Villeneuve Franklin & Hachigian, LLP