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CORRESP

 CONFIDENTIAL SUBMISSION VIA EDGAR

Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Energy & Transportation

 100
F Street, N.E.

 Washington, D.C. 20549

Attention: Myra Moosariparambil and Steve Lo

Re:

China Eastern Airlines Corporation Limited

Form 20-F for the Fiscal Year Ended December 31, 2021

Filed April 28, 2022

File No. 001-14550

 September 8, 2022

Ladies and Gentlemen,

 China Eastern Airlines Corporation
Limited (the “Company” or “we” ) is submitting this letter in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission
(the “SEC”), as contained in your letter, dated August 11, 2022 (the “Comment Letter”), to the Company regarding the Company’s above-referenced annual
report filed on Form 20-F (File No. 001-001-14550) for the fiscal year ended December 31,
2021, filed with the SEC on April 28, 2022 (the “Annual Report”).

 To facilitate your review
of our responses, we have repeated your comment in italics followed immediately by our response.

 Comment No.1:

Please revise to present risk factor disclosures under the heading “Risks Relating to the PRC” more prominently in your filing by placing them
toward the forepart of the Risk Factors section.

 Response No.1:

In response to the Staff’s comments, we hereby propose to place the risk factor disclosures under the heading “Risks Relating to the PRC” toward
the forepart of the Risk Factors section in our next annual report on Form 20-F.

 Comment No.2:

 We note your disclosure indicating that you expect to be identified as a “Commission Identified Issuer” subject to the Holding
Foreign Companies Accountable Act (or HFCAA). Please disclose that you have been identified in the conclusive list of issuers under the HFCAA providing prominent disclosure regarding your identification as an issuer on this list.

Response No.2:

 In response to the
Staff’s comments, we hereby propose to amend the risk factor disclosure in our next annual report on Form 20-F as below, with necessary updates based on future developments:

The HFCAA, was signed into law on December 18, 2020. The HFCAA states if the SEC determines that we have filed audit reports issued by a
registered public accounting firm that has not been subject to inspection for the PCAOB for three consecutive years beginning in 2021, the SEC shall prohibit our shares or ADSs from being traded on a national securities exchange or in the over-the-counter trading market in the United States. On December 2, 2021, the SEC adopted final amendments implementing the disclosure and submission requirements of the
HFCAA, pursuant to which the SEC will identify an issuer as a “Commission Identified Issuer” if the issuer has filed an annual report containing an audit report issued by a registered public accounting firm that the PCAOB has determined it
is unable to inspect or investigate completely, and will then impose a trading prohibition on an issuer after it is identified as a Commission-Identified Issuer for three consecutive years. On December 16, 2021, the PCAOB issued a report to
notify the SEC of its determination that the PCAOB is unable to inspect or investigate completely registered public accounting firms headquartered in mainland China and Hong Kong. The PCAOB identified our auditor as one of the registered public
accounting firms that the PCAOB is unable to inspect or investigate completely. Therefore, we expect to be identified as a “Commission Identified Issuer” after the filing of this Annual Report on Form
20-F. In May 2022, the SEC identified us as a “Commission-Identified Issuer” after the filing of our annual report on Form 20-F for the year ended
December 31, 2021.

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 Comment No.3:

Please provide prominent disclosure about the legal and operational risks associated with being based in or having the majority of your operations in China
to clearly disclose the following:

•

 How these risks could result in a material change in your operations and/or the value of the securities or
could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or become worthless;

•

 How recent statements and regulatory actions by China’s government, such as those related to data
security or anti-monopoly concerns, have or may impact the Company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.

Response No.3:

 In response to the
Staff’s comments, we hereby propose to amend our Annual Report by (i) inserting Appendix A under “Item 3. Key Information—Risk Factors—Risks Relating to the PRC;” and (ii) amending the risk factor disclosure
in our Annual Report as below:

 We are subject to cyber security risks and may incur increasing costs in an effort to minimize those risks.

 The nature of our business involves the receipt and storage of personal information about our customers. We have a program in
place to detect and respond to data security incidents. To date, we have not encountered any material data security incident all incidents we have encountered have been insignificant. If we commit a significant data security
breach or fail to detect and appropriately respond to a significant data security breach, we could be exposed to government enforcement actions and private litigation. In addition, our customers could lose confidence in our ability to protect their
personal information, which could cause them to stop using our services. The loss of consumer confidence from a significant data security breach could hurt our reputation and adversely affect our business, result of operations and financial
condition.

 Actual or anticipated attacks may cause us to incur increasing costs, including costs to deploy additional personnel and
protection technologies, train employees and engage third-party experts and consultants, costs incurred in connection with the notifications to employees, suppliers or the general public as part of our notification obligations to the various
government authorities that govern our business, or costs to dedicate significant resources to system repairs or other increase cyber security protection. We may also be required to pay fines in connection with stolen customer, employee or other
confidential information, or incur significant litigation or other costs.

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 The PRC Data Security Law, which was promulgated on June 10, 2021 and
became effective on September 1, 2021, imposes data security and privacy obligations on entities and individuals conducting data-related activities, and introduces a data classification and hierarchical protection system based on
the importance of data in economic and social development, as well as the degree of harm it will cause to national security, public interests, or legitimate rights and interests of individuals or organizations when such data is tampered with,
destroyed, leaked, or illegally acquired or used. The Personal Information Protection Law, which was promulgated on August 20, 2021 and became effective on November 1, 2021, further emphasizes processors’
obligations and responsibilities for personal information protection and sets out the basic rules for processing personal information and the rules for cross-border transfer of personal information. In October 2020, the Standing
Committee of the National People’s Congress officially released the draft of the Personal Information Protection Law, or the Draft Personal Information Protection Law. The Draft Personal Information Protection Law provides the basic regime for
personal information protection, including without limitation, stipulating an expanded definition of personal information, providing a long-arm jurisdiction in cross-border scenarios, emphasizing individual
rights, and prohibiting rampant infringement of personal information, such as stealing, selling, or secretly collecting personal information. If the Draft Personal Information Protection Law is promulgated as an effective regulation in the future,
As of the date of this Annual Report, we have not been involved in any investigations on data security or privacy compliance issues in connection with the PRC Data Security Law or the Personal Information Protection Law, and we have not
received any inquiry, notice, warning, or sanctions in such respect. However, if we cannot assure you that our business operations do not will comply with such regulation
laws in all respects and we may be involved in investigations by the regulatory authorities and may be imposed fines or ordered to rectify ordered to terminate certain of our business operations that are deemed illegal by the
regulatory authorities and become subject to fines and/or other sanctions.

 Comment No.4:

Please disclose the risks related to being based in or having the majority of the company’soperations in China poses to investors. In particular,
describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion ofthese risks in the filing. In addition, specifically provide the following:

•

 Discuss the risks arising from the legal system in China, including risks and uncertainties regarding the
enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and highlight separately the risk that the Chinese government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of your securities;

•

 Given recent statements by the Chinese government indicating an intent to exert more oversight and control
over offerings that are conducted overseas and/or foreign investment in China-based issuers, acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

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 Response No.4:

In response to the Staff’s comments, we hereby propose to amend our Annual Report by inserting Appendix A under “Item 3. Key
Information—Risk Factors—Risks Relating to the PRC.”

 Comment No.5:

Please disclose each permission or approval that you or your subsidiaries are required toobtain from Chinese authorities to operate your business and to
offer the securities toforeign investors. State whether you or your subsidiaries are covered by permissionsrequirements from the China Securities Regulatory Commission (CSRC), CyberspaceAdministration of China (CAC) or any other governmental agency
and state affirmativelywhether you have received all requisite permissions or approvals and whether anypermissions or approvals have been denied. Please also describe the consequences to youand your investors if you or your subsidiaries: (i) do
not receive or maintain suchpermissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you arerequired to obtain such
permissions or approvals in the future.

 Response No.5:

In response to the Staff’s comments, we hereby propose to amend our Annual Report by (i) inserting Appendix A under “Item 3. Key
Information—Risk Factors—Risks Relating to the PRC”; and (ii) inserting Appendix B under “Item 4. Information on the Company—Regulation.”

Comment No.6:

 Please provide a clear
description of how cash is transferred through your organization, including you, your subsidiaries, CEA Holding and your related parties, and disclose howyou intend to settle amounts in the related party transactions as described at Note 45 toyour
consolidated financial statements. In addition, address the following for the periods presented:

•

 Quantify any cash flows and transfers of other assets by type that have occurred among you, your subsidiaries
and CEA Holding;

•

 Quantify any dividends and distributions that your subsidiaries have made to you and or CEA Holding, indicate
which entities made such transfers;

•

 Quantify dividends or distributions made to U.S. investors, identify the source, and describe their tax
consequences;

•

 Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across
borders, and to U.S. investors;

•

 Describe any restrictions and limitations on your ability to distribute earnings from the Company, including
your subsidiaries to the U.S. investors.

 Response No.6:

The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company is a PRC incorporated company holding equity interest in
its subsidiaries, without adopting a VIE structure for its listing on the NYSE. Except for Eastern Air Overseas (Hong Kong) Corporation Limited (“Eastern Air Overseas”), all subsidiaries of the Company are companies established in the PRC.

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 In response to the Staff’s comments, we hereby propose to amend our Annual Report by inserting the
below content under “Item 5. Operating and Financial Review and Prospects—B. Liquidity and Capital Resources.”

 Cash Flow and Asset
Transfer between the Company, Our Subsidiaries and Related Parties

 The cash flows between the Company and our subsidiaries mainly
comprise: (i) inter-company advances and loans pursuant to our central cash management policy as well as inter-company transactions in connection with asset transfer or otherwise during the normal course of business; (ii) capital
contributions by the Company to our subsidiaries; and (iii) dividends from our subsidiaries to the Company on an annual basis. For the years ended December 31, 2019, 2020 and 2021, the cash flows occurred between the Company and our
subsidiaries included (i) net cash payment from the Company to our subsidiaries arising from inter-company advances, loans and inter-company transactions amounting to RMB8,125 million, RMB18,548 million and RMB4,815 million,
respectively; (ii) capital contribution amounting to RMB600 million, nil and RMB600 million, respectively; and (iii) dividends received amounting to RMB1,578 million, RMB503 million and RMB1,868 million,
respectively. The Company received such dividends from certain of its subsidiaries, mainly comprising Shanghai Eastern Flight Training Co., Ltd., China Eastern Airlines Jiangsu Co., Ltd., China Eastern Airlines Wuhan Co., Ltd., Shanghai Airlines
Co., Ltd., China United Airlines Co., Ltd. and China Eastern Airlines E-Commerce Co., Ltd.

 As for
the cash transactions between the Group and CEA Holding mainly comprise (i) shareholder loans from CEA Holding, (ii) property leases from CEA Holding and (iii) dividends to CEA Holding. For the years ended December 31, 2019, 2020
and 2021, the cash flows occurred between the Group and CEA Holding included (i) drawdown of shareholder loans amounting to RMB300 million and RMB11,000 million in 2019 and 2021, respectively, and repayment of shareholder loans
amounting to RMB828 million in 2021; (ii) rental payments amounting to RMB57 million, RMB71 million and RMB43 million in 2019, 2020 and 2021, respectively; and (iii) earnings distribution in the form of dividends paid by the
Company amounting to RMB254 million in 2020. There were no dividends or other distributions made directly to CEA Holding by our subsidiaries during the years ended December 31, 2019, 2020 and 2021.

We also enter into transactions from time to time with other subsidiaries of CEA Holding. For a description of such transactions, see Note 45
to the consolidated financial statements and “Item 7. Majo