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August 4, 2023
David Leung
Chief Executive Officer
Euro Tech Holdings Company Limited
Unit D, 18/F, Gee Chang Hong Centre
65 Wong Chuk Hang Road
Hong Kong
Re:Euro Tech Holdings Company Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated July 27, 2023
File No. 000-22113
Dear David Leung:
            We have reviewed your July 27, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We note your statement that you are "not owned or controlled by any governmental entity
in any jurisdiction" in connection with your required submission under paragraph
(a).  Please supplementally describe the materials that were reviewed and tell us whether
you relied upon any legal opinions or third party certifications such as affidavits as the
basis for your submission.  In your response, please provide a similarly detailed discussion
of the materials reviewed and legal opinions or third party certifications relied upon in
connection with the required disclosures under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party.  For

 FirstName LastNameDavid Leung
 Comapany NameEuro Tech Holdings Company Limited
 August 4, 2023 Page 2
 FirstName LastName
David Leung
Euro Tech Holdings Company Limited
August 4, 2023
Page 2
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.  In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note that your proposed disclosures pursuant to Items 16I(b)(2), (b)(3) and (b)(5) use
the term “the Company.”  It is unclear from the context of these disclosures whether this
term is meant to encompass you and all of your consolidated foreign operating entities or
whether in some instances these terms refer solely to Euro Tech Holdings Company
Limited as you only identify your subsidiaries pursuant to Item 16I(b)(4).  Please note that
Item 16I(b) requires that you provide each disclosure for yourself and your consolidated
foreign operating entities, including variable interest entities or similar structures.  To
clarify this matter, please provide the information required by each subsection of Item
16I(b) for you and all of your consolidated foreign operating entities.
            Please contact Tyler Howes at 202-551-3370 or Christopher Dunham at 202-551-3783
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Richard Friedman, Esq.