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China Yuchai International Limited

CHINA YUCHAI INTERNATIONAL LIMITED

16 Raffles Quay #26-00 Hong Leong Building Singapore 048581

Tel : (65) 6220 8411     Fax : (65) 6226 0502

August 4, 2006

Via Edgar and Facsimile (1-202) 942-9636

United States Securities and Exchange Commission

Mail Stop 5546

100 F. Street, N.E.

Washington, D.C. 20549

    Attention:

    Cecilia D. Blye

Chief

Office of Global Security Risk

    Peggy Fisher

Assistant Director

Division of Corporation Finance

    James Lopez

    Re:

    China Yuchai International Limited

Form 20-F

Filed July 15, 2005 (File No. 1-13522)

Ladies and Gentlemen:

Set forth below is China Yuchai International Limited’s (“CYI”) response to the Staff’s comments in
Cecilia Blye’s letter dated June 14, 2006. For the Staff’s convenience, the Staff’s comments are
set forth before each response.

General

    1.

    We note public media reports that you export a significant percentage of your international
sales are sales to Cuba, which is identified as a state sponsor of terrorism by the U.S. State
Department and subject to sanctions administered by the U.S. Commerce Department’s Bureau of
Industry and Security and the U.S. Treasury Department’s Office of Foreign Assets Control. We
note that the Form 20-F does not contain any information relating to operations in, or ties
to, Cuba. Please describe your operations in, and ties to, Cuba, if any, and discuss their
materiality to you in light of Cuba’s status as a state sponsor of terrorism. Please also
discuss whether the operations constitute a material investment risk to your security holders.
Your response should describe your current, past and anticipated operations in, and other

    contracts with, Cuba, including through subsidiaries, affiliates, distribution agreements
and other direct and indirect arrangements.

    1.

    CYI confirms to the Staff that a very small number of the diesel engines manufactured by its
Chinese operating subsidiary, Guangxi Yuchai Machinery Company Limited (“Yuchai”), are
exported by Yuchai to Cuba. However, for the reasons set forth below, CYI does not believe
that these export sales are material to its current, past and anticipated operations or to its
security holders.

    Historical unit and revenue data for export sales to Cuba for fiscal years 2003, 2004 and
2005 are set forth in Appendix 1 to this letter. This data shows the insignificance
of these export sales to Yuchai’s operations in these prior three years. For example, in
2005, of the 230,228 diesel engine units sold by Yuchai, only 339 units, or 0.15% of total
production, was exported to Cuba. Similarly, the sales revenue contribution from these
Cuban exports represented only 0.11% of Yuchai’s total sales revenue in 2005. Similar
insignificant unit and revenue data occurred in 2003 and 2004. Given the de minimis nature
of the amounts involved, CYI does not believe that its export sales to Cuba have constituted
a material investment risk to its security holders. Accordingly, CYI believes that no
specific reference was needed to this insignificant export data in its annual report on Form
20-F for the fiscal year ended December 31, 2004 filed on July 15, 2005.

    CYI has reviewed the media reports referred to in the Staff’s comments. It appears that the
recent publicity originated from a memorandum of understanding which was signed on March 31,
2006 between Yuchai, a Chinese export agency and representatives of the Cuban Ministry of
Transportation. The memorandum of understanding contemplates that Yuchai will supply
approximately 20,000 diesel engines to the Cuban government over the next four years. Based
on current market value of such engines spread over four years, relative to Yuchai’s current
and forecasted production and revenue levels, these export sales are not expected to
significantly lift Yuchai’s total production or revenue.

    CYI has included additional information in its Form 20-F for the fiscal year ended December
31, 2005 being filed with the Commission concurrent with this response letter relating to
its export markets (including Cuba) generally, as well as this memorandum of understanding
in particular. CYI has also included a statement confirming its view that sales pursuant to
this memorandum of understanding are not expected to have a material impact on Yuchai’s unit
production or sales revenue. See Item 4. Information on the Company — Business Overview —
Sales, Marketing and Services” of the Form 20-F for the fiscal year ended December 31, 2005.

    2.

    Your materiality analysis should address materiality in quantitative terms, including the
approximate dollar amount of revenues, assets and liabilities associated with Cuba. Please
address materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value. In this regard, we note that Arizona
and Louisiana have adopted legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or permitting divestment of state
pension fund assets from, companies that do business with countries identified as state
sponsors of terrorism. The

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    Pennsylvania legislature has adopted a resolution directing its Legislative Budget and
Finance Committee to report annually to the General Assembly regarding state funds invested
in companies that have ties to terrorist-sponsoring countries. Florida requires issuers to
disclose in their prospectuses any business contacts with Cuba or persons located in Cuba.
Your materiality analysis should address the potential impact of the investor sentiment
evidenced by the referenced legislative actions directed toward companies that have business
contacts with Cuba.

    2.

    Given the de minimis nature of CYI’s dealings with Cuba (outlined above), CYI does not
believe that this represents a material concern for CYI’s investors, from either a
quantitative or qualitative perspective. CYI acknowledges that investor awareness in the
United States and elsewhere has been heightened in recent years regarding investments in
companies which have dealings with state sponsors of terrorism. CYI confirms to the Staff
that it has considered the relevance of such issues to CYI’s present and planned business
activities in preparing its disclosure to investors. However, CYI reiterates that it firmly
believes that such concerns are inapplicable to either CYI or its affiliates.

    3.

    We note disclosure in Hong Leong Asia Ltd.’s “Second Quarter And Half Year Financial
Statement and Dividend Announcement For The Period Ended 30 June 2005” that your parent
company, Hong Leong Asia Ltd., exports products through a subsidiary to North Korea. Please
discuss the materiality of your parent’s business contacts with North Korea to your company,
and whether those contacts constitute a material investment risk for your security holders.
Address specifically the impact Hong Leong Asia’s North Korea contacts may have upon your
reputation and share value. We note, in this regard, the Arizona, Louisiana and Pennsylvania
legislative actions referenced in the preceding paragraph.

    3.

    Historical unit and revenue data for export sales to North Korea by a subsidiary of CYI’s
parent company, Hong Leong Asia Limited (“HLA”), for fiscal years 2003, 2004 and 2005 are set
forth in Appendix 2 to this letter. The HLA subsidiary is Henan Xinfei Electric Co.,
Ltd. and the principal products which it exports are household refrigerators, as well as other
consumer electrical applicances. As with CYI’s dealings with Cuba, these export sales by
CYI’s sister company are immaterial in both quantitative and qualitative terms. Given their
de minimis nature, CYI does not believe that these dealings are material to CYI or its share
value, and therefore do not require specific disclosure in CYI’s periodic filings.

As requested by the Staff, CYI hereby acknowledges that:

    •

    CYI 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

    •

    CYI 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.

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If you have any questions or comments, please do not hesitate to contact Mr. Philip Ting Sii Tien
at (65) 6220 8411.

    Respectfully submitted,

/s/   Philip
Ting Sii Tien

    Philip Ting Sii Tien

    Director and Chief Financial Officer

Enclosures:

    cc:

    Ms. Sheila Murugasu, China Yuchai International Limited

Mr. Michael Sturrock, Latham & Watkins LLP, Singapore

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Appendix 1

Sales of Units of Diesel Engines

by Guangxi Yuchai Machinery Company Limited (“Yuchai”)

to Cuba for the years 2003, 2004 and 2005

    Worldwide

    Cuba

    Total sales revenue

    % of total Yuchai revenue

    Total number of units

    Total Yuchai

    Number of units

    % of total units sold

    by Yuchai to Cuba

    from sales by Yuchai of

    sold worldwide by

    revenue from

    sold by Yuchai

    by Yuchai to Cuba

    in fiscal year

    units to Cuba

    Fiscal Year

    Yuchai in fiscal year

    worldwide unit sales

    to Cuba

    in fiscal year

    (US$)(1)

    in fiscal year

    2003

    172,219

    552,159,729

    130

    0.08

    337,233

    0.06

    2004

    206,628

    674,451,157

    510

    0.25

    1,340,683

    0.20

    2005

    230,228

    704,335,286

    339

    0.15

    802,298

    0.11

    Total

    609,075

    1,930,946,172

    979

    0.16

    2,480,214

    0.13

    (1)

    Amounts have been converted from Chinese Renminbi to United States dollars at a convenience
translation rate of Rmb8.2765 to US$1. Amounts shown are exclusive of rates above.

Appendix 2

Sales of Units of Electronic Goods (Principally Refrigerators)

by Henan Xinfei Electric Co., Ltd. (“Xinfei”)

to North Korea for the years 2003, 2004 and 2005

    Worldwide

    North Korea

    % of total units sold

    Total sales revenue to

    % of total Xinfei revenue

    Total number of units

    Number of units sold

    by Xinfei to

    North Korea by Xinfei

    from sales of units by

    sold worldwide by

    Total revenue from

    by Xinfei to

    North Korea

    in fiscal year

    Xinfei to North Korea

    Fiscal Year

    Xinfei in fiscal year

    worldwide unit sales

    North Korea

    in fiscal year

    (US$)(1)

    in fiscal year

    2003

    1,970,587

    280,350,631

    3,907

    0.20

    388,033

    0.14

    2004

    2,390,084

    358,452,486

    27,224

    1.14

    2,806,919

    0.78

    2005

    2,814,255

    440,144,626

    31,438

    1.12

    3,372,417

    0.77

    Total

    7,174,926

    1,078,947,743

    62,569

    0.87

    6,567,369

    0.61

    (1)

    Amounts have been converted from Chinese Renminbi to United States dollars at a convenience
translation rate of Rmb8.2765 to US$1. Amounts shown are exclusive of rates above.