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December 19, 2023
Wang Hua
Chief Financial Officer
PetroChina Company Limited
9 Dongzhimen North Street
Dongcheng District, Beijing 100007
The People's Republic of China
Re:PetroChina Company Limited
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated October 11, 2023
File No. 001-15006
Dear Wang Hua:
            We have reviewed your October 11, 2023 response to our comment letter and have the
following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 14,
2023 letter.
Form 20-F for Fiscal Year Ended December 22, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 122
1.We note that you do not believe that any members of your board of directors, including
those who are members or officials of the CPC Leadership Team of CNPC, are Chinese
Communist Party officials.  Please clarify the basis for this statement given Article 33 of
the Chinese Communist Party Constitution addresses the leading Party members groups or
Party committees of state-owned enterprises, indicating they should play a leadership role
and discuss and decide on major issues of their enterprise in accordance with
regulations.  In your response, please address the following:

•Please explain to us in reasonable detail the roles and responsibilities of the CPC
Leadership Team of CNPC, including how they participate in deciding the major

 FirstName LastNameWang Hua
 Comapany NamePetroChina Company Limited
 December 19, 2023 Page 2
 FirstName LastName
Wang Hua
PetroChina Company Limited
December 19, 2023
Page 2
issues of their enterprise and the extent to which this group approves and directs
major decisions and activities of their enterprise.

•Please provide us with a detailed explanation of the roles and responsibilities of each
of your directors who is also an official or member of the CPC Leadership Team of
CNPC on PetroChina’s operations and major decisions.

•Please explain to us in more detail how you considered whether the CPC Leadership
Team of CNPC has effectively been appointed by or is effectively acting as an agent
for the Chinese Communist Party and whether the functions of this role would
reasonably meet a definition of a Chinese Communist Party official.

2.We note your responses to prior comment 3 and to comment 4 in our letter dated August
4, 2023. Neither of these responses clearly indicates the steps you have taken to determine
whether any director of any of your consolidated entities is an official of the Chinese
Communist Party or your conclusion as to this matter. As such, we re-issue the
comment. Please tell us whether any member of the board of directors of any of your
consolidated entities is an official of the Chinese Communist Party and supplementally
describe the steps you have taken to confirm this. For 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.
            Please contact Jennifer Gowetski at 202-551-3401 or Jennifer Thompson at 202-551-
3737 with any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Kyungwon Lee