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CORRESP
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     Steven
    M. Skolnick
    One
    Lowenstein Drive

     Partner
    Roseland,
    New Jersey 07068

    T:
    973 597 2476

    F:
    973 597 2477

    E:
    sskolnick@lowenstein.com

February
23, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

Washington,
DC 20549

    Attn:
    Eiko
    Yaoita Pyles

    Re:
    Coffee
    Holding Co., Inc.

    Form 8-K Furnished on January 25, 2023

    File No. 001-32491

Ladies
and Gentlemen:

This
letter sets forth the response of Coffee Holding Co., Inc. (the “Company”) to the comment of the Staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in
your letter, dated January 26, 2023, with respect to the Company’s Current Report on Form 8-K , as furnished to the SEC on January
25, 2023 (the “Current Report”).

For
your convenience, the Staff’s comment is reprinted in bold below, followed by the Company’s response thereto.

The
Company has authorized us to respond to the Comment Letter as follows:

Form
8-K Furnished on January 25, 2023

Item
4.02

1.
Your disclosure appears to indicate that the errors in the consolidated statement of operations for the fiscal year ended October 31,
2020 is only included in your Form 10-K for the fiscal year ended October 31, 2021. If this error is included in your other filings,
please revise to disclose as such in your Form 8-K. Also amend your Form 10-K for the fiscal year ended October 31, 2020, if applicable,
and amend your Form 10-Q to the extent the errors have any effect on your fiscal 2022 Form 10-Qs.

Response: The Company acknowledges the Staff’s
comment and respectfully advises the Staff that after further analysis by the Company’s management and accounting staff, and in
consultation with its auditors, the Company has determined to restate the previously filed financial statements for the fiscal year ended
October 31, 2020 and October 30, 2019 included in the associated Form 10-K for the fiscal year ended October 31, 2020 originally filed
with the SEC on February 16, 2021, as amended on February 26, 2021. Further, to correct errors in the Company’s accounting for certain
intercompany eliminations in its consolidated statements of operations for the fiscal periods ended January 31, 2020, April 30, 2020 and
July 31, 2020 (collectively, the “2020 Interim Periods”), the Company will be amending the Quarterly Reports on Form 10-Q
filed for the fiscal periods ended January 31, 2021, April 30, 2021 and July 31, 2021 in order
to correct the comparative periods presented therein to reflect adjustments made to correct errors in the Company’s accounting for
certain intercompany eliminations during such 2020 Interim Periods.

    Securities and Exchange Commission

Division of Corporation Finance

February 23, 2023

Page 2

Further, the Company respectfully advises the Staff that it
has determined that there are no material misstatements in any interim financial statements during the fiscal years ended October 31,
2021 or 2022 included in any previously filed Quarterly Report on Form 10-Q and the Company does not currently have an intention to restate
or amend those reports.

Any
questions regarding the contents of this letter should be addressed to the undersigned at (973) 597-2476.

Very
truly yours,

    /s/
    Steven M. Skolnick

    Steven M. Skolnick

    cc:
    Andrew
    Gordon, Coffee Holding Co., Inc.