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CORRESP
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CORRESP

 December 28, 2022

Division of Corporation Finance

 Office of Energy &
Transportation

 Securities and Exchange Commission

 100 F
Street, NE

 Washington, DC 20549

Re:
 PetroChina Company Limited

Form 20-F for Fiscal Year Ended December 31, 2020

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

Response dated August 31, 2022

File No. 001-15006

 Dear Sir/Madame,

 I refer to the further comments set forth in the letter dated October 31, 2022 (the “Letter”) from the staff (the
“Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) relating to the annual reports of PetroChina Company Limited (“PetroChina” or the “Company”) on Form
20-F for the fiscal years ended December 31, 2020 and 2021, and the Company’s responses to the comments filed with the Commission on August 31, 2022. Set forth below are the Company’s
responses to the comments in the Letter. The numbered paragraphs below correspond to the comments in the Letter, which have been retyped below in bold for your ease of reference.

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

Risk Factors

 Risks Related to Government
Regulation, page 7

1.
 We note from your disclosure on page 1 that you exclude Hong Kong and Macau from your definition of
“PRC” or “China” for the purpose of your annual report. Please clarify that all the legal and operational risks associated with having operations in the People’s Republic of China also apply to operations in Hong Kong and
Macau. In this regard, please ensure that your disclosure does not narrow risks related to operating in the PRC to mainland China only. Where appropriate, you may describe PRC law and then explain how law in Hong Kong and Macau differs from PRC law
and describe any risks and consequences to the company associated with those laws. As an example, please further expand the risk factor on page 21 to also provide disclosure related to the enforceability of civil liabilities in Hong Kong and Macau.

 Response:

The Company respectfully advises the Staff that its business in the Hong Kong Special Administrative Region (“Hong Kong”) mainly
includes oil and gas trading, investment and retail. As it does not have any business in the Macau Special Administrative Region (“Macau”), the Company’s discussion in this letter does not cover Macau.

 1

 Over the years, the reference to “China” in the annual reports of the Company on
Form 20-F have not covered Hong Kong, Macau and Taiwan. The Company has been advised by King & Wood Mallesons (“KWM”), its external counsel to PRC and Hong Kong laws, that Hong Kong is not
subject to those PRC mainland regulations that have an impact on the Company and as discussed under the “Risks Related to Government Regulations” section, including the Chinese economic policies, industry policies, laws and regulations
with respect to mining rights, foreign exchange, pricing, taxation, general commercial affairs, anti-monopoly, foreign investment restrictions, data security reviews, etc. Therefore, “Risks Related to Government Regulation” is limited to
the discussion of the risks associated with the Company’s exposure to government regulation in the mainland of China, except for the securities regulation of Hong Kong in connection with the Company’s listing of shares on The Stock
Exchange of Hong Kong Limited (“HKSE”).

 The Company’s business operations in Hong Kong conducted through its Hong Kong
entities are subject to Hong Kong laws, regulations and government supervisions in terms of commerce, business, tax, finance, labor, customer personal data protection, etc. The regulatory authorities of the mainland of China do not regulate the
business operations of the Company’s Hong Kong entities.

 Generally, for a cross-border investment project in a foreign country, Hong
Kong, Macau or Taiwan that is pursued by an enterprise in the mainland of China, the mainland enterprise needs to comply with the approval and/or filing requirements of the regulatory authorities in the mainland of China. Once an enterprise obtains
the required approvals or completes the required filings, it can legally obtain and use the foreign exchange for that project, set up a local entity (or entities) in the foreign country, Hong Kong, Macau or Taiwan, and conduct business through the
local entities. There is no extraterritorial regulation by the mainland regulators over the business activities carried out by such entities incorporated overseas (including Hong Kong, Macau and Taiwan), although the mainland regulators may have an
indirect impact on the operations of overseas entities by regulating the domestic controllers of such entities.

 As advised by its external
PRC counsel, KWM, PRC regulations presently do not require the Company to cease, materially change or limit, in part or in whole, its trading, investment and retail business in Hong Kong, limit the development prospects of such business, nor require
the Company not to comply with any law and regulation of Hong Kong, which could have a material adverse effect on the Company’s trading, investment and retail business in Hong Kong and maintaining the listing status on the HKSE. As advised by
its external Hong Kong counsel, KWM, the current regulatory environment in Hong Kong has no material adverse effect on the Company’s investment, trading and retail business in Hong Kong or maintaining a listing status on the HKSE. Based on the
foregoing, the Company submits that it is not necessary to separately disclose a risk factor relating to the Hong Kong laws and regulations in the Risk Factor section of its 20-F.

 2

 In response to the Staff’s comment on expanding the risk factor on page 21 to also
provide disclosure related to the enforceability of civil liabilities in Hong Kong, the Company would amend the “Risks Related to the Enforceability of Securities Law Liabilities against Our Officers and Directors” in its future 20-Fs as follows:

 “Risks Related to the Enforceability of Securities Law Liabilities against
Our Officers and Directors

 PRC laws and regulations have their foundation in written laws, and PRC laws, regulations and legal
requirements dealing with economic matters continue to evolve. PRC laws and regulations are different in certain material areas such as legislation, judicial system, and enforcement from those in the United States and other common law jurisdictions.
Because of the non-binding nature of prior court decisions in China, the enforcement of laws, regulations and legal requirements involve some degree of uncertainty. Given that the PRC laws and regulations with
respect to companies, securities and litigation are different in certain important aspects from those in the United States and other common law jurisdictions, and most of our assets are located in the PRC and most of our directors and substantially
all of our executive officers reside in the PRC, it may be difficult for our shareholders (including investors of our ADSs) to enforce any judgments against our assets or the assets of our directors and officers located in China in an event that
they believe their rights have been infringed and even if they successfully bring an action against us or our directors and officers and they are successful in an action of this kind.

The ability of U.S. government agencies, such as the U.S. Securities and Exchange Commission, or the SEC, and the U.S. Department of Justice,
or the DOJ, to investigate and bring enforcement actions against us may be constrained by the PRC laws. For example, the securities regulators of the U.S. cannot directly enter into China to carry out investigations and collect evidence, but need to
resort to the regulatory cooperation channels with the regulatory authorities in China, and the DOJ can only conduct investigations through bilateral judicial assistance channels with the PRC judicial authorities. According to Article 177 of the PRC
Securities Law, the securities regulatory authority under the State Council of China may establish a supervision and administration cooperation mechanism with the securities regulatory authorities of other countries or regions for cross-border
securities supervision and administration, and no foreign securities regulator is allowed to directly conduct investigations or evidence collection activities within the territory of China. Without the consent of the securities regulatory department
of the State Council and other competent authorities under the State Council, no organization or individual may provide documents or materials relating to securities business activities to overseas parties.

Where an effective civil judgment or ruling of a foreign court requires recognition and enforcement by a court in China, a party may apply
directly to a court in China which has the jurisdiction or apply to the foreign court for the foreign court to request recognition and enforcement by a court in China according to the treaty concluded or acceded to by China with the home country of
the party or under the principle of reciprocity. After examining an application or request, if the court deems that the judgment or ruling does not violate the basic principles of the laws of China and the sovereignty, national security and public
interest of China, the court shall issue a ruling to recognize the legal validity of the judgment or ruling and issue an order for enforcement as needed to enforce the judgment or ruling. If the court deems that the judgment or ruling violates the
basic principles of the laws of China or the sovereignty, national security or public interest of China, the court will not grant recognition and enforcement. Where an arbitration award of a foreign arbitral tribunal requires recognition and
enforcement by a court in China, a party shall apply directly to the court at the place of domicile of the party against whom enforcement is sought or at the place where the property of that party is located, and the court shall process the
application in accordance with the treaty concluded or acceded to by China or under the principle of reciprocity.

 3

 Civil judgments of U.S. courts cannot be directly enforced in Hong Kong either. At present,
there are no treaties or other arrangements between the U.S. and Hong Kong for reciprocal enforcement of foreign judgments. However, common law permits an action to be brought upon a foreign judgment. Because a judgment can be regarded as creating a
debt between the parties, the foreign judgment itself may form the basis of the cause of action. To enforce a foreign judgment in Hong Kong, a common law action for debt must be brought and the enforcement of a foreign judgment in Hong Kong is
subject to a number of conditions, including but not limited to: (a) the foreign judgment is a final judgment on the merits of the case; (b) the judgment is a judgment on liquidated damages in a civil action and not on taxes, fines, or
similar complaints; (c) the proceedings in which the judgment was obtained were not contrary to natural justice; and (d) that the enforcement of the judgment is not contrary to the public policy of Hong Kong. In addition, there is a six-year limitation period from the date of the foreign judgment to commence enforcement proceedings under common law in Hong Kong. The defenses that are available to a defendant in a common law action brought on
the basis of a foreign judgment include lack of jurisdiction, fraud, or inconsistency of any previous judgment of a Hong Kong court or a foreign judgment recognized in Hong Kong.

As a result of the reasons including but not limited to the foregoing, our foreign public shareholders may have difficulty and face
uncertainties in protecting their interests through actions against our company, directors, officers or our majority shareholder. Shareholder protection through actions initiated by the SEC, DOJ and other U.S. government agencies may also be
limited. ”

2.
 Please further expand your disclosure to address how regulatory actions related to data security or
anti-monopoly concerns in Hong Kong or Macau have impacted 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:

 The Company
respectfully advises the Staff that the Company has been advised by KWM that as the PRC government’s regulations on data security and anti-monopoly are not appliable to Hong Kong, such regulations do not impact the Company’s ability to
conduct its business in Hong Kong, accept foreign investments or list on a U.S. or other foreign exchange.

3.
 Please further expand your disclosure to explain whether there are any commensurate laws or regulations in
Hong Kong or Macau which result in oversight over data security and explain how this oversight impacts the company’s business and the offering and to what extent the company believes that it is compliant with the regulations or policies that
have been issued.

 4

 Response:

The Company respectfully advises the Staff that personal information is protected under Hong Kong law. The Company operates more than a dozen
gas stations in Hong Kong via its subsidiary incorporated in Hong Kong, and the provision of gas station services involves the collection and use of customers’ personal data for processing customers’ application for fuel cards and
providing them with various gas station services. The Hong Kong subsidiary of the Company strictly implements the Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”) in terms of the purpose of information collection, the method of
collection, the method of retention and the retention period, use of the information and others. When a customer of the Hong Kong subsidiary applies for a fuel card, the Hong Kong subsidiary provides the customer with a notice to customers relating
to PDPO, which includes, (a) obtaining consent to the collection and use of the customer’s personal data, (b) explaining to the customer the purpose for which it collects, and (c) explaining to customers their rights to access or
correct personal data, etc. Upon receipt of personal data provided by a customer, the Hong Kong subsidiary will check and store the relevant personal data in a place with strict security or on a server system with security measures such as
firewalls. The server system is managed by the Hong Kong subsidiary itself, and the relevant personal data will only be accessible and archived by authorized employees. The personal data collected by the Company will only be used for fuel cards and
gas station services, and if it is intended for other purposes, the Hong Kong subsidiary will notify the relevant customer in advance and obtain his/her written consent. The original personal data collected by the Hong Kong subsidiary will be
destroyed after the expiration of the prescribed retention period. The Hong Kong subsidiary’s personal data collection policy is also available on its website for the public’s reference. If the Hong Kong subsidiary violates the provisions
of the PDPO, it may be subject to fines and/or other penalties. The Company does not believe that its business in Hong Kong and its ability to list on the U.S. and other exchanges will be affected by the requirement to comply with the PDPO.
Considering that its gas station business in Hong Kong accounts for a very low proportion of its overall business and the risks posed by the PDPO are low, the Company believes that there is no need to include this in the risk factor disclosure in
its 20-F.

4.
 We note from your response to prior comment 4 that you will add risk factor disclosure under the heading of
‘Cash and Asset Flows within Our Organization,’ and that this risk factor disclosure addresses payment of dividends to your shareholders. We further note disclosure indicating that the PRC withholding tax rate is 10% for non-resident enterprise shareholders and that there are different rates for n