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CORRESP
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CORRESP

瑞生國際律師事務所有限法律責任合夥

 18th Floor, One Exchange Square

 8
Connaught Place, Central

 Hong Kong

 Tel:
+852.2912.2500 Fax: +852.2912.2600

 www.lw.com

香港中環康樂廣場八號交易廣場第一座十八樓

 FIRM / AFFILIATE OFFICES

Austin

Milan

Beijing

Munich

Boston

New York

July 10, 2023

Brussels

Orange County

Century City

Paris

Chicago

Riyadh

VIA EDGAR

Dubai

San Diego

Düsseldorf

San Francisco

Sasha Parikh, Staff Accountant

Frankfurt

Seoul

Kevin Vaughn, Senior Associate Chief Accountant

Hamburg

Shanghai

Austin Pattan, Staff Attorney

Hong Kong

Silicon Valley

Andrew Mew, Senior Assistant Chief Accountant

Houston

Singapore

Doris Stacey Gama, Attorney

London

Tel Aviv

Jason Drory, Attorney

Los Angeles

Tokyo

Office of Life Sciences

Madrid

Washington, D.C.

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-7010

                        Re:

 SINOVAC BIOTECH LTD

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

 Filed May 1, 2023

File No. 001-32371

 Dear Ms. Parikh, Mr. Vaughn, Mr. Pattan, Mr. Mew, Ms. Gama, Mr. Drory:

On behalf of our client, Sinovac Biotech Ltd. (the “Company” or “Sinovac Antigua”), we are submitting this
letter setting forth the Company’s responses to the comments contained in the letter dated June 26, 2023 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2022 (the “2022 20-F”).

For ease of review, the Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included
page references in the 2022 20-F where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the 2022 20-F.

Annual Report on Form 20-F

 Introduction,
page 1

1.
 We note your carve-out of Hong Kong and Macau in your definition of “China” and the
“PRC.” Please clarify that the legal and operational risks associated with operating in China also apply to operations in Hong Kong and Macau. Revise to clarify which of your entities are domiciled in or have operations in Hong Kong and/or
Macau, and discuss the applicable laws and regulations in Hong Kong and/or Macau, as applicable, as well as the related risks and consequences.

 Resident Partners:

 Amy E. Beckingham

Andrew J. Bishop

 Benjamin B. R. Carale

Derek S. H. Chua

 Simon J. Cooke

 Kieran G. C. Donovan

 Dominic A. Geiser

Simon M. Hawkins

 Howard K. H. Lam

Posit Laohaphan

 Dominik Sklenar

 Qiuning Sun

 Terris C. C. Tang

Allen C. Wang

 Richard Watkins

See Wah Wong

 Cheung Ying Yeung

 Registered Foreign Lawyers:

 Michael J. S. Hardy
(England and Wales)

 Won Suk Kang (England and Wales)

 Ji Liu
(California)

 Zhonghua Shi (New York)

 Benjamin P. Su (New
York)

 Daying Zhang (New York)

 July 10, 2023

 Page
 2

 In response to the Staff’s comment, the Company will revise the definition of
“China”, “PRC” or Chinese” on page 1 to include Hong Kong and/or Macau, and only exclude Hong Kong and/or Macau in the context of describing laws, rules, regulations, regulatory authorities in mainland China, and any
mainland China entities or citizens under such rules, laws and regulations and other legal or tax matters, with the changes set forth in Annex A.

The Company respectfully advises the Staff that the Company has three subsidiaries domiciled in Hong Kong, namely Sinovac Biotech (Hong Kong)
Limited (“Sinovac Hong Kong”), Everthrive Holding Company Limited and Everthrive Investment (Hong Kong) Company Limited. The business of Sinovac Hong Kong is immaterial to the group’s business. In 2022, sales by Sinovac Hong
Kong only accounted for 1.5% of the group’s total sales. Everthrive Holding Company Limited and Everthrive Investment (Hong Kong) Company Limited had no operation and held no assets as of the date of 2022 20-F.

The Company respectfully advises the Staff that the Company has no subsidiary domiciled and no operations in Macau.

In response to the Staff’s comment, the Company respectfully advises the Staff that it will revise the disclosure under “Item 3. Key
Information – D. Risk Factors—Risks Related to Government Regulation—We may not be able to comply with applicable GMP standards and other regulatory requirements, which could have a material adverse effect on our business, financial
condition and results of operations” on page 21 and the risk factor under “Item 3. Key Information – D. Risk Factors—Risks Related to Doing Business in China—Future changes in laws, regulations or enforcement policies in
China and the PRC government’s oversight and discretion over our operations could adversely affect our business”, with the changes set forth in Annex A, to include Sinovac Hong Kong’s risk of doing business in Hong
Kong.

2.
 You state ““Sinovac,” “Sinovac Biotech,” “Company,” “we,”
“us,” “our company,” and “our” refer to Sinovac Biotech Ltd., its predecessor entities and its consolidated subsidiaries” and that “Sinovac Antigua” refers to Sinovac Biotech Ltd. Clearly disclose how you
will refer to the holding company and subsidiaries when providing the disclosure throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business
operations. For example, disclose, that your subsidiaries conduct operations in China.

 In response to the
Staff’s comment, the Company will to the extent appropriate and practicable, replace terms such as “we” or “our” when describing the activities or functions of the operating subsidiaries in mainland China with “Mainland
China Subsidiaries”, which is defined as the group of the Company’s operating subsidiaries in mainland China, with the changes set forth in Annex A. The Company acknowledges the Staff’s comment and respectfully advises
the Staff that in its future filings on Form 20-F, the Company will reduce using such terms as noted in the Staff’s comment.

 Cash and Asset
Flows Through Our Organization, page 2

3.
 Provide a clear description of how cash is transferred through your organization. Disclose your intentions
to distribute earnings. We note you are paid dividends by your subsidiaries, please quantify the dividends or distributions that a subsidiary has made to the holding company and which entity made such transfer, and their tax consequences. Quantify
any cash flows that have occurred between the holding company and its subsidiaries, and direction of transfer. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make
clear if no transfers or distributions have been made to date. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

 July 10, 2023

 Page
 3

 The Company respectfully advises the Staff that cash is transferred through its organization
by way of capital contributions, intra-group loans and payments for services and dividend distribution. Considering the substantial intra-group transactions and settlements primarily relating to inter-group services which all have been eliminated at
the consolidation level, it would be excessively burdensome for the purpose of annual report disclosure to list out all the intra-group transactions and settlements.

The Company respectfully advises the Staff that Sinovac Antigua did not receive any dividend from its subsidiaries and there was no cash
transfer between Sinovac Antigua and its subsidiaries in 2022. Sinovac Antigua did not distribute any dividend and did not distribute any dividend to investors, including U.S. investors, in 2020, 2021 and 2022, and has no intention to distribute
dividends in the near future.

 In 2022, $263.2 million in dividends were paid by Sinovac Life Sciences Co., Ltd. (“Sinovac
LS”) to Sinovac Hong Kong and its other shareholders, and Sinovac Hong Kong did not further distribute such dividends to Sinovac Antigua. Pursuant to the double tax arrangement between Hong Kong and PRC, dividends paid by a foreign-invested
enterprise in mainland China to its direct holding company in Hong Kong will be subject to withholding tax at a rate of 5% (if the foreign investor owns directly at least 25% of the shares of the foreign-invested enterprise for a period greater than
12 months and meets the relevant requirements pursuant to the tax arrangement between Hong Kong and PRC), or otherwise at 10%. Under Hong Kong tax laws, Sinovac Hong Kong is subject to Hong Kong Profits Tax rate at 16.5%, and is exempted from income
tax on its foreign-derived income. There are no withholding taxes in Hong Kong on remittance of dividends.

 The Company respectfully refers
the Staff to the relevant disclosure regarding restrictions on payment of dividends by our subsidiaries in mainland China under “Item 3. Key Information—Cash and Asset Flows Through Our Organization”, “Item 3. Key Information
– D. Risk Factors—Risks Related to Doing Business in China – We rely on dividends paid by our PRC subsidiaries for our cash needs. If they are unable to pay us sufficient dividends due to statutory or contractual restrictions on their
abilities to distribute dividends to us, our various cash needs may not be met”, “Item 3. Key Information – D. Risk Factors—Risks Related to Doing Business in China—Restrictions on currency exchange may limit our ability to
receive and use our revenues effectively”, “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Dividend Policy” and “Item 10. Additional Information — D. Exchange
Controls”. Certain of the major restrictions and limitations on the payment of dividends from our subsidiaries in mainland China include but not limited to, (i) payment of dividends can only be permitted out of accumulated profits as
determined in accordance with accounting standards and regulations in mainland China, (ii) Sinovac LS is required to set aside at least 10% of its after-tax profits each year to contribute to its reserve fund until the accumulated balance of
such reserve fund reaches 50% of the registered capital of the company, and such reserves are not distributable as cash dividends, and (iii) the ability of our subsidiary to convert renminbi into U.S. dollars and make payments to offshore
parent company is subject to PRC foreign exchange regulations and the approval of SAFE.

 July 10, 2023

 Page
 4

 Part I

Item 3. Key Information, page 2

4.
 At the onset of Part I, please disclose prominently that you are not a Chinese operating company but an
Antiguan holding company under the laws of Antigua and Barbuda with operations conducted by your subsidiaries. In addition, we note your company’s corporate structure diagram on page 47, please provide it earlier in the Key Information section.

 In response to the Staff’s comment, the Company respectfully advises the Staff that it will revise the
disclosure under “Item 3. Key Information — D. Risk Factors—Risk Factors Summary” on page 3 of the 2022 20-F where the Company discloses that it is a holding company that does not directly engage in business operations itself,
with changes set forth in Annex A.

 In response to the Staff’s comment, the Company will move its corporate structure
under “Item 3. – Key Information” on page 3 after “Cash and Asset Flows Through our Organization” and before “Item 3. Key Information – A. Reserved”, with changes set forth in Annex A.

5.
 We note your disclosure regarding regulatory actions by China’s government and impact. Please also
include how such statements or actions 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.

In response to the Staff’s comment, the Company respectfully advises that the Staff that it will revise the risk factor under “Item
3. – Key Information – Permissions Required from the PRC Authorities for Our Operations” on page 2, with changes set forth in Annex A.

6.
 Disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese
authorities to operate your business and to offer securities to foreign investors. We note your discussion of the China Securities Regulatory Commission (CSRC) and Cyberspace Administration of China (CAC) beginning on page 26, please state whether
you or your subsidiaries are covered by permissions requirements from the CSRC, CAC, or any other governmental agency that is required to approve your operations, and state affirmatively whether you have received all requisite permissions or
approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals,
(ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

 The Company respectfully advises that the Staff that it will (i) revise the risk factor under “Item 3.
– Key Information – D. Risk Factors—Risks Related to Doing Business in China—Future changes in laws, regulations or enforcement policies in China and the PRC government’s oversight and discretion over our operations could
adversely affect our business” on page 26, (ii) add a separate risk factor in relation to the recent regulations issued by CSRC under “Item 3. – Key Information – D. Risk Factors—Risks Related to Doing Business in
China—We may be required to complete filing procedures with CSRC in connection with our future offerings, and we cannot predict whether we will be able to complete such filing on a timely manner, or at all” on page 27 after “Item 3.
– Key Information – D. Risk Factors—Risks Related to Doing Business in China—Future changes in laws, regulations or enforcement policies in China and the PRC government’s oversight and discretion over our operations could
adversely affect our business.” and before “Item 3. – Key Information – D. Risk Factors—Risks Related to Doing Business in China—Complying with evolving laws and regulations regarding cybersecurity, information
security, privacy and data protection and other related laws and requirements may be expensive and may force us to make adverse changes to our business. Many of these laws and regulations are subject to change and uncertain interpretation, and any
failure or perceived failure to comply with these laws and regulations could result in negative publicity, legal proceedings, suspension or disruption of operations, increased cost of operations, or otherwise harm our business.”, and
(iii) revise the disclosure under “Item 3. Key Information—Permissions Required from the PRC Authorities for our Operations” on page 2, with both changes set forth in Annex A.

 July 10, 2023

 Page
 5

 Future changes in laws, regulations or enforcement policies..., page 26

7.
 We note your risk factor disclosure regarding the China Securities Regulatory Commission (CSRC) recent
regulation relating to overseas offerings and listings by PRC companies that went into effect March 31, 2023. Please revise to state whether the Provisional Measures apply to the company and discuss potential risks to investors if the company
were to be found noncompliant.

 The Company respectively informs the Staff that the Provisional Measures will only
apply if the Company is engaging in capital raising activities. The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will (i) add a separate risk factor under “Item 3. – Key Information –
D. Risk Factors – Risks Related to Doing Business in China – We m