SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

March 26, 2009
Via U.S. Mail and Facsimile (65-6226-0502)

Teo Tong Kooi
President and Director China Yuchai International Limited 16 Raffles Quay #26-00 Hong Leong Building Singapore 048581
 Re: China Yuchai International Limited
  Form 20-F for the Fiscal Year Ended December 31, 2007
  Filed January 30, 2009   File No. 1-13522
Dear Mr. Kooi:

We have limited our review of your filing to disclosure relating to your contacts
with countries that have been  identified as a state sponsor of terrorism, and we have the
following comments.  Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues.   At this juncture,
we are asking you to provide us with supplemental information, so that we may better understand your disclosure.  Please be as deta iled as necessary in your response. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comment or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. We note from disclosure on page 28 that your subsidiary Guangxi Yuchai sells
products in Cuba and is pa rty to a memorandum of understanding with the Cuban
government for the sale of diesel engines.   As you know, Cuba is identified by the
U.S .Department of State as a state sponsor of terrorism,  and is subject to U.S.
asset controls and export controls.  Pl ease describe to us any transactions,
contracts, agreements and understandings you have entered into with Cuba since

Teo Tong Kooi
China Yuchai International Limited
March 26, 2009 Page 2
your letters to us of August 4, 2006 and September 2, 2006.  In this regard, we note a July 2007 news article stating that  Guangxi Yuchai intends to expand its
export business and hopes to eventually increase exports  to about 30% of its
production.
2. Please provide an updated materiality analys is of your operations associated with
Cuba, including their potential impact upon your reputation and share value since
your letter to us of August 4, 2006.  As  you may be aware, various state and
municipal governments, uni versities, and ot her investors have proposed or
adopted divestment or similar initiatives regarding investment in companies that do business with state sponsors of terroris m.  Your materiality analysis should
address the potential impact of the inve stor sentiment evidenced by such actions
directed toward companies that have operations associated with Cuba.
3. Please tell us whether your  contacts with the Middle East and Africa are still
limited to Turkey and Egypt as set fort h in your letter to us of August 4, 2006.
4. We note a July 22, 2008 website article stat ing that Guangxi Yuchai established a
strategic cooperation relationship with  Zonda Bus/Zonda Group and that Zonda
Bus’s buses have been exported to Syri a.  Syria is identified by the U.S.
Department of State as a state sponsor of terrorism, and is subject to U.S.
economic sanctions and export controls.  Please describe the nature of Guangxi Yuchai’s strategic relationship with Zonda, including a description of any
agreements Guangxi Yuchai and Zonda are party to and whether Guangxi Yuchai
sells diesel engines to Zonda.  Please tell us whether Zonda exports or has
exported buses or any other products to Sy ria that use Guangxi Yuchai’s engines
or other products.
5. We note a July 2007 article stating that Yuchai Group, a parent company of China
Yuchai International Ltd., obtained an orde r to export 1,000 diesel engines to Iran.
Iran is identified by the U.S. Department of  State as a state sponsor of terrorism,
and is subject to U.S. economic sanctions and export controls.
Your Form 20-F does not include any disc losure regarding Yuchai Group.  Please
describe to us your relationship with Yu chai Group and tell us why information
about this entity is not disclosed in y our Form 20-F.  To the best of your
knowledge, understanding and belief, describe  to us the nature and extent of
Yuchai Group’s business contacts with Iran, if any, including the products,
equipment, components, technology, or services Yuchai Group has provided or
provides into Iran, and any arrangements or other contacts Yuchai Group has had
with the Iranian government  or entities cont rolled by that government.  Tell us
whether the diesel engines cited in the report were manufactured, designed or
otherwise provided by Guangxi Yuchai.

Teo Tong Kooi
China Yuchai International Limited
March 26, 2009 Page 3
6. We note January 2009 and October 2008 news  articles statin g that Donfeng
Company and Dongfeng Automob ile Co., Ltd. sell trucks and vehicles in Iran.
Please tell us whether your engines or other products are used in trucks or
vehicles sold to Iran.

* * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a re sponse.  Please submit your response letter on EDGAR.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that th e filings include all in formation required under
the 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 the 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
filings;
 • staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

Teo Tong Kooi
China Yuchai International Limited March 26, 2009 Page 4
Please understand that we may have addi tional comments after we review your
response to our comment.  Pl ease contact Jennifer Hardy, Special Counsel, at (202) 551-
3767 if you have any questions about the commen t or our review.  You may also contact
me at (202) 551-3470.          S i n c e r e l y ,

          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk   cc:  Peggy Fisher   Assistant Director  Division of Corporation Finance