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CORRESPONDENCE

9 Raffles Place

#42-02 Republic Plaza

Singapore 048619

Tel: +65.6536.1161 Fax: +65.6536.1171

www.lw.com

 UEN No. T09LL1649F

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July 10, 2023

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United States Securities and Exchange Commission

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Washington, D.C.

 100 F Street, N.E.

 Washington,
D.C. 20549

 Attention: Karl Hiller, Branch Chief

        Yong Kim, Staff Accountant

Re:
 China Yuchai International Limited

Form 20-F for the Fiscal Year ended December 31, 2022

Filed April 26, 2023

File No. 001-13522

Ladies and Gentlemen:

 On behalf of China Yuchai
International Limited, a Bermuda company (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by the staff (the “Staff”) of the Securities and Exchange Commission in its
comment letter dated June 9, 2023 with respect to the Form 20-F for the Fiscal Year ended December 31, 2022 (the “Form 20-F”).

The Staff’s comments are repeated below in italic and are followed by the Company’s responses. We have included page references to
the Form 20-F where a response refers to the revised disclosure therein. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Form
20-F.

 Form 20-F for the Fiscal Year ended December 31, 2022

 Risk Factors, page 8

1.
 Please expand the risk factor disclosure on page 19, under the heading “Our financial condition,
results of operations, business and prospects may be adversely affected if we are unable to implement the Reorganization Agreement and the Cooperation Agreement,” to clarify the status and relevance of these agreements, which you indicate were
formulated during the period 2003-2007, and to identify the counterparties in the agreements and to describe your present relationship with those counterparties.

Given your disclosure stating that non-compliance with the continued expansion and diversification
provisions of these agreements “could have a material adverse effect” on your financial condition, results of operations, business or prospects, we believe that you should describe your obligations concerning business expansion and
diversification, including quantification of any relevant metrics, specification of milestones and timelines, and any contractual or reasonably possible consequences for non-compliance.

 July 10, 2023

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 2

 The disclosure expressing uncertainty as to whether such requirements will be fully
implemented, or if implementation will effectively resolve all of the difficulties regarding your investment in Yuchai, should also be modified to clarify the extent to which you have been unable to comply with such requirements since entering into
the agreements, to include a description of the obstacles that you have encountered and any options or alternatives that you may have to resolve such matters.

Response:

The Company respectfully submits that the Reorganization Agreement, as amended, and the Cooperation Agreement continue to be in
force and effect. These agreements are also available as exhibits to the Form 20-F and prior filings by the Company. The parties to the Reorganization Agreement include the Company, its subsidiary, Guangxi
Yuchai Machinery Company Limited (referred to as “Yuchai” in the Form 20-F) and Coomber Investments Limited, (referred to as “Coomber” in the Form
20-F). Coomber is wholly owned by Goldman Industrial Limited, which in turn is a wholly-owned subsidiary of Guangxi Yuchai Machinery Group Company Limited (“GY”, which together with its subsidiaries
is referred to as the “GY Group” in the Form 20-F), which in turn is a majority-owned subsidiary of the State-owned Assets Supervision and Administration Commission of the People’s Government of
Guangxi Zhuang Autonomous Region.

 The parties to the Cooperation Agreement include the Company, Yuchai, Coomber and GY.
Coomber is a shareholder of the Company, and GY is a shareholder of Coomber. The Company does not have any financial relationship with Coomber or the GY Group. The Company has various commercial arrangements with the GY Group as disclosed in the
Form 20-F. For example, during fiscal year 2022, Yuchai and its affiliates entered into agreements with the GY Group and its affiliates for, among other things, sales of engines and parts to the GY Group,
purchase of parts, supplies and engines from the GY Group, and other business relating to, among other things, hospitality, lease of assets, property management services, and delivery, storage, distribution and handling services. In addition, Yuchai
and GY are the two shareholders of Guangxi Yuchai Machinery Monopoly Development Co., Ltd with 71.8% and 28.2% shareholding interest, respectively.

In response to the Staff’s comment, the Company undertakes to revise the risk factor in its future filings to further
clarify the parties to the agreements and the relevance of these agreements as follows (underline indicates additional text and strikethrough indicates deleted text):

“Our financial condition, results of operations, business and prospects may be adversely affected if we are unable to implement the
Reorganization Agreement and the Cooperation Agreement.

 We own 76.4% of the outstanding shares of Yuchai, and one
of our primary sources of cash flow continues to be our share of the dividends, if any, paid by Yuchai and investment earnings thereon. As a result of the agreement reached with Yuchai and its related parties pursuant to the July 2003 Agreement, we
discontinued legal and arbitration proceedings initiated by us in May 2003 relating to difficulties with respect to our investment in Yuchai. In furtherance of the terms of the July 2003 Agreement, we, Yuchai and Coomber Investments Limited, or
Coomber, entered into the Reorganization Agreement in April 2005, as amended in December 2005 and November 2006, and agreed on a restructuring plan intended to be beneficial to our shareholders. Coomber is wholly owned by Goldman Industrial
Limited which in turn is a wholly owned subsidiary of GY which in turn is a majority-owned subsidiary of the State-owned Assets Supervision an Administration Commission of the People’s Government of Guangxi Zhuang Autonomous Region. The
Reorganization Agreement provides for the implementation of corporate governance guidelines approved by the directors and shareholders of Yuchai in November 2002 and outlines steps for the adoption of corporate governance practices at Yuchai
conforming to international custom and practice.

 July 10, 2023

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 3

 The Reorganization Agreement was scheduled to terminate on
June 30, 2007. In JuneOn June 30, 2007, we, along with Yuchai, Coomber and the GY Group entered into the Cooperation Agreement. The
Cooperation Agreement amends certain terms of the Reorganization Agreement and, as so amended, incorporates the terms of the Reorganization Agreement. The Reorganization Agreement, as amended, and the Cooperation Agreement continue to be in force
and effect. Pursuant to the amendments to the Reorganization Agreement, the Company has agreed that the restructuring and spin-off of Yuchai will would
not be effected, and, recognizing the understandings that have been reached between the Company and the GY Group to jointly undertake efforts to expand the business of Yuchai, the Company will not seek to recover the anti-dilution fee of
US$20 million that was due from Yuchai. For more information on these agreements see “Item 4. Information on the Company — A. History and Development of the Company.” No assurance can be given as to when the business expansion
requirements relating to Yuchai as contemplated by the Reorganization Agreement and the Cooperation Agreement will be fully implemented, or that implementation of the Reorganization Agreement and the Cooperation Agreement will effectively resolve
all of the difficulties faced by us with respect to our investment in Yuchai.

 In addition, the Reorganization Agreement
as amended by the Cooperation Agreement contemplates the continued implementation of our business expansion and diversification plan adopted in February 2005. The Cooperation Agreement provides that the parties will explore
new business opportunities and ventures with a view to diversifying and expanding the assets, business divisions, sources of revenue and operations of Yuchai. One of the goals of this business expansion and diversification plan is
to reduce our financial dependence on Yuchai. Subsequently, we acquired strategic stakes in HLGE and TCL (which we have since substantially divested). See “Item 5. Operating and Financial
Review and Prospects — A. Overview — Business Expansion and Diversification Plan.” In addition, Yuchai has entered into various strategic alliances, including joint ventures, with various
third parties to further our business purpose. For example, Yuchai has entered into a 45% joint venture with Jirui United Heavy Industry Co., Ltd. and Shenzhen City Jiusi Investment Management Limited, a 50-50 joint venture with MTU Friedrichshafen GmbH and a 65% joint venture with Beijing Xing Shun Da Bus Co., Ltd, and Yuchai’s wholly-owned subsidiary, Guangxi Yuchai Exhaust
Technology Co., Ltd., has entered into a 49% joint venture with Purem International GmbH. Nonetheless, no assurance can be given that we will be able to successfully expand and diversify our business. We may also not be able
to continue to identify suitable acquisition opportunities, secure funding to consummate such acquisitions or successfully integrate such acquired businesses within our operations. Any failure to implement the terms of the Reorganization Agreement
and Cooperation Agreement, including our continued expansion and diversification, could have a material adverse effect on our financial condition, results of operations, business or prospects. Additionally, although the Cooperation Agreement amends
certain provisions of the Reorganization Agreement and also acknowledges the understandings that have been reached between us and the GY Group to jointly undertake efforts to expand and diversify the business of Yuchai, no assurance can be given
that we will be able to successfully implement those efforts or as to when the transactions contemplated therein will be consummated.”

The Company respectfully submits that while the Reorganization Agreement and the Cooperation Agreement contemplate the
continued implementation of a business expansion and diversification plan with a view to diversifying and expanding the assets, business divisions, sources of revenue and operations of Yuchai, the agreements do not specify any metrics, milestones or
timelines. The Company therefore believes that no further disclosure is required in this regard.

 The Company further
respectfully submits that the Company believes it has been in full compliance with its obligations under the Reorganization Agreement, as amended, and the Cooperation Agreement. The Company has not experienced any legal or regulatory obstacles in
meeting such obligations. The Company notes that as described above, the Company has acquired strategic stakes in HL Global Enterprises Limited and Thakral Corporation Ltd (which the Company has since divested) and Yuchai has entered into several
strategic alliances, including joint ventures, in furtherance of its obligations under these agreements.

 July 10, 2023

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 4

2.
 We note your risk factor disclosures on pages 11 and 12, under the heading “We are or may be subject to
risks associated with strategic alliances, including joint ventures,” explaining that Yuchai Xin-Lan New Energy Power Technology Co., Ltd. (“Yuchai Xin-
Lan”), was formerly a wholly-owned subsidiary of Guangxi Yuchai Machinery Company Limited (“Yuchai”) though since February 2023 has been an 87.7% owned subsidiary of Yuchai, and we see corresponding illustration in your organizational
chart on page 39.

 Please reconcile these disclosures with information provided in your subsequent events
disclosure on page F-91, explaining that “the Group’s equity interest in Yuchai Xin-Lan decreased from 69.5 % as of December 31, 2022 to 67.0 %”
in connection with the entity receiving various capital contributions from other investors.

 Please also expand your disclosure
regarding the conveyance of Yuchai Xin-Lan (Jiangsu) Hydrogen Energy Technology Co., Ltd to Yuchai Xin-Lan, as necessary to describe the terms of the transaction
including the circumstances/precipitating events or rationale for the conveyance, along with an indication of its significance.

Response:

The Company respectfully submits that the Company’s subsidiary, Guangxi Yuchai Machinery Company Limited (referred to as
“Yuchai” in the Form 20-F), owns an 87.7% equity interest in Yuchai Xin-Lan New Energy Power Technology Co., Ltd. (referred to as “Yuchai Xin-Lan” in the Form 20-F) since February 2023 following investments from three unrelated third-party investors between November 2022 and February 2023. As the Company
owns 76.4% of the outstanding shares of Yuchai, the Company’s effective equity interest in Yuchai Xin-Lan was 67.0% as of February 28, 2023. The Company undertakes to clarify the disclosure regarding
the Company’s equity interest in Yuchai Xin-Lan in its future filings.

 In
March 2023, Yuchai transferred its wholly-owned subsidiary, Yuchai Xin-Lan (Jiangsu) Hydrogen Energy Technology Co., Ltd (“Xin-Lan Hydrogen”) to Yuchai Xin-Lan. As Xin-Lan Hydrogen became a wholly-owned subsidiary of Yuchai Xin-Lan through the transfer, the Company’s effective
equity interest in Xin-Lan Hydrogen was reduced to 67.0%. The conveyance of Xin-Lan Hydrogen was effected in furtherance of the Company’s strategic research and
development plans for new energy solutions. The Company submits that the foregoing does not have a material effect on its consolidated financial statements for the year ended December 31, 2022 and undertakes to revise the disclosure to reflect
the foregoing in its future filings.

3.
 We note that you have provided various risk factor disclosures that appear to be responsive to some of the
concerns identified in our December 2021 sample letter to China Based Companies, which may be viewed our website at the following address:

https://www.sec.gov/corpfin/sample-letter-china-based-companies.

However, we believe that some incremental disclosures should be provided to further clarify certain matters as identified in the comments
that follow, which include references to existing disclosures that could be expanded to include this information, although you may suggest alternate placement for such incremental disclosures.

Please submit the specific language that you propose to address these concerns, including any associated revisions to the summary of risk
factors provided on pages 3 and 4.

 July 10, 2023

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 5

 Response:

In response to the Staff’s comment, the Company undertakes to revise the summary of risk factors in future filings as
follows (underline indicates additional text):

 “Risks Related to Our Business and Industry

•

 The diesel engine business in China is dependent in large part on the performance of the Chinese and the global
economy. Adverse economic developments in China or in the global economy could have a material adverse effect on our financial condition, results of operations, business or prospects.

•

 The diesel engine business in China is dependent in large part on relevant government policies. As a result, our
financial condition, results of operations, business and prospects could be adversely affected by changes in government policies in