SecProbe.io

December 4 , 2012

Via Facsimile
Leong Kok Ho
Chief Financial Officer
China Yuchai International Limited
16 Raffles Quay
#39-01A Hong Leong Building
Singapore 048581

 Re: China Yuchai International Limited
  Form 20-F for the Fiscal Year Ended December 31, 2011
  Filed April 19 , 2012
  File No. 1 -13522

Dear M r. Ho:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors 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 information so we may
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts a nd circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General
1. Please tell us about any contacts with Cuba, Iran and Syria since your letter to us of April
23, 2009.  Please also tell us about any contacts with Sudan. We note for instance the
disclosure on page 34 regarding exports to Cuba, and note that Guangxi Yuchai’s website
lists international sales offices for Syria, Iran and Cuba, and a sal es representative for
Sudan.  Cuba, Iran, Syria and Sudan are identified by the U.S. Department of State as
state sponsors of terrorism, and are subject to U.S. economic sanctions and export
controls.  Your Form 20 -F does not include disclosure regarding c ontacts with Iran, Syria
and Sudan.  Please describe to us the nature and extent of your past, current, and
anticipated contacts with Iran, Syria, Sudan or Cuba, whether through subsidiaries,
resellers, distributors, or other direct or indirect arrangement s. Include information about
Guangxi Yuchai and Dongfeng Group, which, according to news reports, sells products
in Iran, Syria and Sudan.  Your response should describe any products, equipment,

Leong Kok Ho
China Yuchai International Limited
December 4 , 2012
Page 2

 components, technology, and services you have provided to the  referenced countries, and
any agreements, commercial arrangements, or other contracts you have had with the
governments of these countries or entities controlled by these governments.
2. Please discuss the materiality of your contacts with Cuba, Iran, Syria  and Sudan described
in response to the foregoing comment and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period .  Also, address
materiality in terms of qualitative factors that a reasonable investor would deem important
in making an investment decision, includ ing the potential impact of corporate activities
upon a company’s reputation and share value.  Various state and municipal governments,
universities, and other investors have proposed or adopted divestment or similar initiatives
regarding investment in com panies that do business with U.S. -designated state sponsors of
terrorism.  Your materiality analysis should address the potential impact of the investor
sentiment evidenced by such actions directed toward companies that have operations
associated with Cuba , Iran, Syria and Sudan.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules  require.  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 responding to our comments, please provide a wr itten 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.

Leong Kok Ho
China Yuchai International Limited
December 4 , 2012
Page 3

 Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Amanda Ravitz
  Assistant Director
 Division of Corporation Finance