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    WWW.MAGSTONELAW.COM

    293 Eisenhower

    Parkway Suite 135

    Livingston NJ 07039
    415 S Murphy Ave

    Sunnyvale

    Ca 94086
    1180 Avenue of the

    Americas 8th Floor

    New York, NY 10036
    1 Raffles Place -

Tower 2, #20-61

 Singapore 048616

July 24, 2023

Division of Corporation
Finance Office of Life Sciences

U.S. Securities and Exchange
Commission

100 F Street, NE

Washington, DC 20549

    Re:

    Heyu Biological Technology Corp

    Form 10-K for the Fiscal Year Ended December
    31, 2022

    Filed March 23, 2023

    File No. 000-26731

Dear Sir/Madam,

On behalf of Heyu Biological
Technology Corp (the “Company”), we set forth below responses to the comment letter of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) dated as of July 12, 2023 with respect to the Form 10-K
for the Fiscal Year ended December 31, 2022 (File No. 000-26731) filed by the Company on March 23, 2023, as amended by Amendment No.1
to Form 10-K filed by the Company on June 22, 2023 (the “Form 10-K Amendment”). For your convenience, the Staff’s
comments are repeated below in bold and italics, followed in each case by the responses of the Company. Page references are made to the
Form 10-K Amendment to illustrate the approximate location of the disclosure.

Amendment No. 1 to Form 10-K for the Fiscal Year Ended December
31, 2022

Item 7. Management’s Discussion and Analysis of
Financial Condition and Results of Operations Results of Operations, page 17

1. Please provide us with your proposed revised disclosure to be included in future filings to address
the following:

 ● Revise your Business section and MD&A to more clearly
identify your products and revenue streams.

The Company acknowledges
the Staff’s comment and intends to include in the Business section and MD&A of its future Form 10-K filings the following disclosure,
with revisions reflecting the relevant fiscal years discussed in each such filing:

Products

We offer disinfectant
sprays, healthcare instruments and other healthcare related products. We derive our revenue primarily through the sale of disinfectant
sprays and healthcare instruments. Revenue from the sale of disinfectant sprays accounted for 29.4% and 26.6% of our total revenues for
the fiscal years ended December 31, 2022 and December 31, 2021, respectively. Revenue from the sale of healthcare instruments accounted
for 65.1% and 73.4% of our total revenues for the fiscal years ended December 31, 2022 and December 31, 2021, respectively.

 ● Provide a breakdown of your revenues and cost of goods sold by product type. To the extent your
tabular breakdown of your Cost of revenues (i.e. Disinfectant sprays, Healthcare instruments and Other) on page 18 represents the way
you view your product types, revise your future filings to break out revenues earned for the periods presented into the same categories.
Provide us with such a breakdown in your response.

The Company acknowledges the Staff’s comment and intends
to include the following disclosure in its future Form 10-K filings, with revisions reflecting the relevant fiscal years discussed in
each such filing:

Page 18:

The following chart provides a summary of our
revenues for the fiscal years ended December 31, 2022 and 2021, respectively.

    For the Year Ended December 31,

    2022
    2021

    USD
    %
    USD
    %

    Revenue – related parties, net:

    Disinfectant sprays
      23,202
      29.39 %
      25,663
      26.60 %

    Healthcare instruments
      51,419
      65.13 %
      70,815
      73.40 %

    Others
      4,332
      5.49 %
      -
      -

    Total
      78,953
      100.0 %
      96,478
      100.0 %

    2

 ● Expand your disclosure on page 17 to describe the reasons for the increase in revenue. For example,
discuss the extent to which changes in revenue were driven by prices vs volumes and the degree to which specific products or groups of
products impacted sales levels.

Page 17:

The Company acknowledges the Staff’s comment and intends
to include the following disclosure in its future Form 10-K filings, with revisions reflecting the relevant fiscal years discussed in
each such filing:

We sold 2,500 bottles of disinfectant sprays at
an average price of USD9.28 per bottle in 2022, in comparison to 2,710 bottles of disinfectant sprays at an average price of USD9.47 per
bottle in 2021. We sold 36 healthcare instruments at an average price of USD1,428.30 in 2022, in comparison to 16 healthcare instruments
at an average price of USD4,425.93 in 2021. The decrease in annual revenue in 2022 from 2021 is primarily due to the lower average price
of the healthcare products sold.

 ● Revise the disclosure on page 17 to clarify whether all of the revenue is related party. Your disclosure
on page F-15 states that all of your products are sold to your Chief Executive Officer and director of the Company, Mr. Ban Siong Ang.
However, the disclosure on page 17 states that you sign a purchase and sale agreement with a customer, the customer then makes payment
to Mr. Ban Siong Ang which is transferred to the Company, and then the goods are delivered to the customer. Please clarify if the products
are sold to third party customers or only to Mr. Ban Siong Ang. Revise to clearly explain the business purpose of such an arrangement.

In response to the Staff’s comment, the Company proposes to make the following revisions (underlined) to the last paragraph of “Note
9 – Related Party Transactions” on Page F-15 in its future Form 10-K filings, with revisions reflecting the relevant fiscal
years discussed in each such filing:

All of our products are sold to our Chief Executive Officer
and director of the Company, Mr. Mr. Ban Siong Ang. For the years ended December 31, 2022 and 2021, the Company earned revenues from Mr.
Ban Siong Ang, in the amount of $78,593 and $96,478, respectively. As customers made payments to Mr. Ban Siong Ang first, who in turn
passes the payments onto the company, all sales are deemed have been made to Mr. Ban Siong Ang for financial reporting purpose.

In addition, the Company intends to include the following disclosure
in its future Form 10-K filings, with revisions reflecting the relevant fiscal years discussed in each such filing:

Page 17:

All of our revenue is currently derived from related party
transactions. The end customers are either Mr. Ban Siong Ang’s immediate family members or close friends which the Company have
identified as related parties. By routing the sales through Mr. Ban Siong Ang, the company can effectively track sales, manage customer
relationships, and provide personalized service to its customers. This arrangement in the past has allowed for efficient sales management
and a streamlined process for delivering the goods to customers. However, due to accounting and corporate governance considerations, the
Company has stopped routing sales through Mr. BAN Siong Ang effective on July 1, 2023, and now requires customers to make payments directly
to the Company.

 ● The revenue recognition section you added on page 18 only addresses the
payment deposit. Please provide us revised disclosure to be included in future filings to also include the revenue recognition policy
for the orders disclosed on page 17.

In response to the Staff’s comment, the
Company intends to add the following disclosure:

Until July 1, 2023, we would sign a purchase and sale agreement with
a customer upon receiving the customer’s order. The customer would make payment to Mr. Ban Siong Ang, our Chairman and CEO, which
payment will then be transferred by Mr. Ban Siong Ang to the Company. Upon receipt of the payment, it would be classified as “Advances
from customers”. We would deliver the goods to the customer or make the goods available for pick-up at our principal executive offices
typically within one to two weeks from the payment date. After delivery of the goods to the customer, the payment would be recognized
as revenue.

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The Company will continue to recognize revenue for goods sold after
delivery is made to customers.

2. The disclosure you added on page 18 states that you
have classified the deposit received from the customer as “unearned revenue”. However, it appears that it is classified as
“Advances from customers” on the Balance Sheet. Please clarify. In addition, please explain why the deposit is classified
as a current liability since you disclose that you are currently unable to determine when the revenue can be recognized.

The Company hereby informs the Staff that the deposit should
have been classified as “Advances from customers.” The deposit is current liability because the customer may request a full
refund at any time prior to the Company having obtained the regulatory license for selling the product. The Company intends to identify
the deposit as “Advances from customers” in its future Form 10-K filings.

3. We note that you added a Cost of Revenue section on
page 18. Please confirm that in future filings you will add a line item for Cost of Revenue to the table on page 17 so that it is clear
to an investor that the balance is also included in the computation of Loss from Operations.

In response to the Staff’s comment, the Company intends
to add in its future Form 10-K filings line items “Cost of Revenue” and “Gross Profits” (indicated in italics)
to the financial table set forth below, with revisions reflecting the relevant fiscal years discussed in each such filing:

    Fiscal Year ended
 December 31,

    2022
    2021

    Revenue – related parties, net
    $ 78,953
    $ 96,478

    Cost of revenue
      27,385
      30,315

    Gross profits
      51,568
      66,163

    Total operating expenses
      317,347
      228,999

    Loss from operations
      (265,779 )
      (162,836 )

    Total other income (expense)
      200
      (184 )

    Income tax
      -
      -

    Net loss
    $ (265,579 )
    $ (163,020 )

    Basic net loss per share
    $ (0.00 )
    $ (0.00 )

*****

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Thank you for your consideration in reviewing
the above responses. We note that all proposed future disclosures remain subject to further revision in response to business and regulatory
developments that may affect the Company between now and the filing of its next annual report. If you have any questions or wish to discuss
any aspect of the 2022 Form 10-K, please contact the undersigned by phone at 347.989.6327 or by e-mail at markli@magstonelaw.com.

    Very truly yours,

    /s/ Yue (Mark) Li

    Yue (Mark) Li

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