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China Petroleum & Chemical Corporation

22 Chaoyangmen North Street

Chaoyang District, Beijing, 100728

The People’s Republic of China

October 13,
2023

VIA EDGAR

Mr. Tyler Howes

Mr. Christopher Dunham

Division of Corporation Finance

Disclosure Review Program

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    China Petroleum & Chemical Corporation

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

    Response dated September 1, 2023 (“First Response Letter”)

    File No. 001-15138

Dear Mr. Howes
and Mr. Dunham:

We refer to the letter dated September 15, 2023 from
the staff (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) with
respect to certain comments regarding the annual report on Form 20-F of China Petroleum & Chemical Corporation (the “Company”)
for the fiscal year ended December 31, 2022 filed with the Commission on April 28, 2023 (the “2022 Form 20-F”). Set
forth below are our responses to the Staff’s comments. For your convenience, we have also restated the Staff’s comments
below in bold.

*          *          *

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

Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 99

 1. We note your response to comment 1 and the disclosure related to your subsidiaries in Note 39 to your consolidated financial statements.
Please note that Item 16I(b) of Form 20-F states: “Also, any such identified foreign issuer that uses a variable-interest
entity or any similar structure [emphasis added] that results in additional foreign entities being consolidated in the financial
statements of the registrant is required to provide the below disclosures for itself and its consolidated foreign operating entity or
entities.” Additionally, page 15 of our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,”
clarifies that a registrant should “look through a VIE or any structure [emphasis added] that results in additional foreign
entities being consolidated in the financial statements of the registrant and provide the required disclosures about any consolidated
operating company or companies in the relevant jurisdiction.” As previously requested, please revise to provide the information
required by Items 16I(b)(2) through (b)(5) for all of your consolidated foreign operating entities.

With
respect to Items 16I(b)(2) and (3), the Company respectfully advises the Staff that the Company does not have or otherwise
use any VIE or similar structure “that results in any additional foreign entities being consolidated in the financial statements”
of the Company other than its subsidiaries. Given that China Petrochemical Corporation, a company controlled by the State-owned Assets
Supervision and Administration Commission of the State Council of China, holds 67.84% of the shares in the Company, Chinese governmental
entity has a controlling financial interest in the Company and its subsidiaries, and owns, indirectly through the Company, the corresponding
equity interests in the wholly-owned subsidiaries of the Company. In addition, the following table sets forth the information with respect
to the shareholding structure of the Company’s principal subsidiaries disclosed under Note 39 to the consolidated financial statements
included in the 2022 Form 20-F that are not wholly owned by the Company.

    Principal Subsidiaries(1)
    Shareholding by
 the Company
 (%)
    Shareholding by Other
 Entities Controlled by PRC
 Governmental Entities
 (%)
    Shareholding
 by Other
 Entities
 (%)

    Sinopec Beihai Refining and Chemical Limited Liability Company
      98.98 %
      1.02 %
      0 %

    ZhongKe (Guangdong) Refinery & Petrochemical Company Limited
      90.30 %
      9.70 %
      0 %

    Sinopec Qingdao Refining and Chemical Company Limited
      85.00 %
      15.00 %
      0 %

    Sinopec Marketing Company Limited
      70.42 %
      11.60 %
      17.98 %

    Sinopec Kantons Holdings Limited
      60.33 %
      N/A  (2)

    Sinopec-SK (Wuhan) Petrochemical Company Limited
      59.00 %
      6.00 %
      35.00 %

    Sinopec Shanghai Gaoqiao Petrochemical Co., Ltd.
      55.00 %
      45.00 %
      0 %

    Sinopec Baling Petrochemical Co., Ltd.
      55.00 %
      45.00 %
      0 %

    Sinopec Shanghai Petrochemical Company Limited
      50.44 %
      N/A  (3)

    Fujian Petrochemical Company Limited
      50.00 %
      50.00 %
      0 %

 Notes:

 1. Other than Sinopec Kantons Holdings Limited, which is incorporated in British Virgin Islands, all principal subsidiaries of the Company
are incorporated in China. To the knowledge of the Company, no governmental entity of British Virgin Islands holds any shares in its principal
subsidiaries set forth in the table above.

 2. Sinopec Kantons Holdings Limited is a public company listed on the main board of the Hong Kong Stock Exchange. According to the annual
report filed by Sinopec Kantons Holdings Limited with the Hong Kong Stock Exchange on April 14, 2023, as of December 31, 2022,
the Company indirectly owned 60.33% of the shares in Sinopec Kantons Holdings Limited, and the other shareholders (including public investors)
owned the remaining 39.67%.

 3. Sinopec Shanghai Petrochemical Company Limited is a public company listed on the main board of the Hong Kong Stock Exchange. As of
December 31, 2022, the Company indirectly owned 50.44% of the shares in Sinopec Shanghai Petrochemical Company. According to the
annual report on Form 20-F filed by Sinopec Shanghai Petrochemical Company Limited with the Commission on April 26, 2023, as
of March 31, 2023, the Company owned 50.55% of the shares in Sinopec Shanghai Petrochemical Company Limited, and the other shareholders
(including public investors) owned the remaining 49.45%.

    2

With respect to Item 16I(b)(5), the Company respectfully
confirms that no articles of association of the Company’s subsidiaries contains any charter of the Communist Party of China.

With
respect to Item 16I(b)(4), please refer to the Company’s response to Comment No. 2 as set forth below.

 2. We note your response to comment 2 identifying four directors as CCP officials. Please revise your annual report consistent with
your response. Please also provide us with your analysis with respect to each of your other five directors, including whether or not such
directors have any involvement in CCP matters, including your consideration of current and prior CCP memberships or affiliations with
the CCP. For example only, we note that Liu Hongbin has served on multiple CPC Committees, and that Cai Hongbin served as a member of
the National People's Congress. Finally, please also identify any directors of your subsidiaries who are officials of the Chinese Communist
Party.

The Company respectfully submits that it will file an amendment
to the 2022 Form 20-F to incorporate the Company’s response to Comment No. 2 set forth in the First Response Letter. In
addition, the Company respectfully confirms that, as of the date of the 2022 Form 20-F, none of the other 5 directors of the Company
held any position in the Leading Party Member Group of China Petrochemical Corporation. Specifically, (i) Mr. Liu Hongbin ceased
to hold any position in the Leading Party Member Group of China Petrochemical Corporation, which is the last position he held within the
Communist Party of China, in November 2021, and (ii) the National People’s Congress is not an organization of the Communist
Party of China and Mr. Cai Hongbin is not a member of the Communist Party of China.

The Company also respectfully submits to the Staff that,
as of the date of the 2022 Form 20-F, none of the directors of the Company’s subsidiaries held any position in the abovementioned
committee of the Communist Party of China.

 3. We note your response to comment 3. Please also explain the scope of your review as applied to the boards of your consolidated
foreign operating entities.

The Company respectfully submits to the Staff that (i) the
Company maintains human resources records of each executive director of the consolidated foreign operating entities of the Company; and
(ii) the Company has requested each non-executive director (including each independent director) of the consolidated foreign operating
entities of the Company to submit his or her biographical information to the Company, prior to his or her appointment to the board, and
to notify the Company of any updates thereof. As part of the Company’s annual compliance and reporting procedures for the Form 20-F
filing, the Company has reviewed the relevant information.

    3

The Company respectfully submits that it did not rely upon
any third party certifications such as affidavits as the basis of its disclosure.

*          *          *

Please
contact Alpine Wu, at (832) 834-2431 or alpinewu@sinopec.com if you have any questions. Thank you very much.

    Sincerely,

    China Petroleum & Chemical Corporation

    By:
    /s/ Huang Wensheng

    Name:
    Huang Wensheng

    Title:
    Vice President and Secretary to the Board of Directors

    4