SecProbe.io

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

 DIVISION OF
CORPORATION FINANCE

December 21, 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
  Response letter filed December 18, 2012

Dear Mr. Ho:

We have reviewed your response letter and have the following comments.

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 and 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. We note your response to comment 1 in our letter dated December 4, 2012.  You
state that you sold an insignificant percenta ge of products directly into Cuba
through the expiration of the memorandum of understanding in 2010.  Please tell
us the amounts of direct unit and revenue sales into Cuba and the percentage of
total sales those amounts represented, for 2009 and 2010, as t he information in
Appendix I relates only to indirect unit and revenue sales into Cuba and the other
countries covered.

Leong Kok Ho
China Yuchai International Limited
December 21, 2012
Page 2

 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