SecProbe.io

January 22, 2015

Via E -mail
Si Chen
Chief Executive Officer and President
American Lorain Corporation
BeihuanZhong Road
Junan County
Shandong, People’s Republic of China, 276600

Re: American Lorain Corporation
 Form 10-K for Fiscal Year Ended December 31, 2013
Filed March 31, 2014
Response dated January 16, 2015
File No. 1 -34449

Dear  Mr. Chen :

We have reviewed your response letter  dated January 16, 2015 and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Resu lts of Operations, page
26

Liquidity and Capital Resources, page 31

1. We note your response to prior comment 2.  The two indentures that you reference appear
to be material contracts that should be filed as exhibits to the Form 10 -K.  Amend your
Form 10 -K to file those documents.  Also, in future filings, please provide investors with
a more detailed discussion of your fundraising efforts, the purposes of such efforts and
their impact on your operating results, capital expenditures, an d liquidity.  Please provide

Si Chen
American Lorain Corporation
January 22, 2015
Page 2

 us with draft disclosure to be included in your next filing, including a brief description of
the material terms of your debt instruments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure , they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Karina V. Dorin, Attorney -Advisor,  at (202) 551 -3763  or me at (202) 551 -
3745  with any other questions.

Sincerely,

 /s/H. Roger Schwall

H. Roger S chwall
Assistant Director