SecProbe.io

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								September 8, 2005

Mr. Wilman Wong
Chief Financial Officer
Chai-Na-Ta Corp.
Unit 100 - 11300 No. 5 Road
Richmond, B.C. V7A 5J7

	Re:	Chai-Na-Ta Corp.
		Form 20-F for Fiscal Year Ended December 31, 2004
Filed April 4, 2005
      File No. 0-20386

Dear Mr. Wong:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

Selected Financial Data, page 3

1. It appears from your disclosures that you have not included
depreciation relating to property, plant and equipment in your
determination of Gross Profit.  Please revise your calculation to
include all costs and expenses associated directly with or
allocated
to your product sold.  These costs and expenses should include
inventoriable costs of assets incident to or necessary for
cultivation of your product, including applicable depreciation,
depletion and amortization.  Refer to SAB Topic 11:B.  In
addition,
revise any discussion throughout your filing of Gross Profit, as
appropriate.

Risk Factors, page 6

2. We note your disclosure under this heading as follows: "The
Ministry of Commence of the People`s Republic of China announced
an
order to stop the import of cultivated North American ginseng to
China for the purpose of contract processing in China and then re-
export.  The announcement was effective on November 1, 2004 but it
is
still premature to predict the impact of this measure on the
prices
of ginseng root."  Please tell us how you have considered the
impact
this announcement will have on the impairment of your inventory
and
capitalized crop costs.  In addition, please expand your liquidity
discussion to discuss the ways in which this announcement could
impact your business and your ability to continue as a going
concern.

Major Shareholders and Related Party Transactions, page 27

3. We note your disclosure that "Any issued and outstanding
preferred
shares will automatically be converted into common shares in
2010."
In view of the mandatory conversion of these shares into common
stock
in 2010, please tell us how you have considered the guidance in
paragraph 15 of CICA 3861 and paragraph 9 of SFAS 150 for purposes
of
the US GAAP reconciliation.

Financial Statements

Consolidated Statements of Cash Flows

4. We note that you present a reconciliation of net earnings after
items not affecting cash in footnote 15(a).  Please support your
disclosure of this subtotal under Canadian GAAP as there does not
appear to be a provision within CICA 1540 for this presentation.

Note 18. Differences Between Canadian and United States Generally
Accepted Accounting Principles

5. We note your disclosure under part (e) that the write-down of
inventory and crop costs is included in operating expenses under
Canadian GAAP and cost of goods sold under US GAAP.  Based on this
disclosure, please explain the reason why Canadian GAAP net
earnings
would be increased for the write-down of inventory of $192,642 to
reconcile to US GAAP net earnings.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Jennifer Goeken at (202) 551-3721 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3683 with any other
questions.

								Sincerely,

								Jill S. Davis
								Branch Chief
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Mr. Wilman Wong
Chai-Na-Ta Corp.
September 8, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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