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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

September 29, 2006

Via Edgar and Facsimile (1-202) 772 9208

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

Division of Corporate Finance

    Re:

    China Yuchai International Limited

Form 20-F

Filed July 15, 2005

    Response Letters Dated August 4, 2006 and September 7, 2006

(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 September 27, 2006. For the Staff’s convenience, the Staff’s comments
are set forth before each response.

General

    1.

    We note your response to prior comments two. Please confirm, if true, that Xinfei conducts
its North Korean operations independent of you and your employees, and that Xinfei’s North
Korean expenses and revenues do not affect your expenses and revenues. If, however, you or
your subsidiaries’ operations are affected by Xinfei’s North Korean operations, please discuss
such overlapping or interrelated operations and expand your materiality analysis to take into
account the North Korean contacts. For example, if you or your subsidiaries’ operations are
affected by Xinfei’s North Korean operations, express revenues from those operations as a
percentage of your

    own total sales revenues, instead of as a percentage of Xinfei’s total sales revenues, and
identify the significant factors underlying your conclusion that such North Korean contacts
are qualitatively immaterial.

    1.

    CYI confirms to the Staff that Henan Xinfei Electric Co., Ltd. (“Xinfei”), a subsidiary of
CYI’s parent company, Hong Leong Asia Limited, conducts its North Korean operations
independent of CYI and its employees. CYI further confirms to the Staff that expenses and
revenues relating to Xinfei’s North Korean operations do not affect CYI’s expenses and
revenues.

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

    cc:

    Ms. Sheila Murugasu, China Yuchai International
Limited

Mr. Michael Sturrock, Latham & Watkins LLP, Singapore

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