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    SIPP
    International Industries, Inc.
    50
    West Liberty Street

                                                           Suite 880

    Reno,
    NV 89501

June
22, 2023

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

Attention: Eiko
Yaoita Pyles

Ernest
Greene

Thomas
Jones

Geoff
Kruczek

 Re: SIPP
International Industries, Inc.

Registration
Statement on Form S-1

Filed
May 10, 2023

File
No. 333-271830

Dear
Sir or Madam:

SIPP
International Industries, Inc. (the “Company”) is filing amendment number 1 (the “Amendment”) to the Registration
Statement on Form S-1 (the “Registration Statement”) in response to your recent review letter addressed to Min Jiang, Chief
Executive Officer of the Company, dated June 6, 2023 (the “SEC Letter”). This response letter, along with the amended Offering
Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the SEC Letter.

Registration
Statement on Form S-1 filed May 10, 2023

Cover
Page

1.
Please disclose prominently on the prospectus cover page that you are not a Chinese operating company but a Nevada holding company with
operations conducted by your subsidiaries based in China and that this structure involves unique risks to investors. Provide a cross-reference
to your detailed discussion of risks facing the company and the offering as a result of this structure.

While
we had previously included much of the requested disclosure at the bottom of the cover page, we have moved it to a more prominent spot
and expanded as appropriate.

2.
Provide prominent disclosure about the legal and operational risks associated with being based in or having the majority of the company’s
operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or
the value of the securities you are registering for sale or could significantly limit or completely hinder your ability to offer or continue
to offer securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should
address how recent statements and regulatory actions by China’s government, such as those related to the use of variable interest
entities and data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business, accept
foreign investments, or list on a U.S. or other foreign exchange. Please disclose the location of your auditor’s headquarters and
whether and how the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations
will affect your company. Your prospectus summary should address, but not necessarily be limited to, the risks highlighted on the prospectus
cover page.

While
we had previously included much of the requested disclosure in the middle of the cover page, we have moved it to a more prominent spot
and expanded as appropriate.

3.
Clearly disclose how you will refer to the holding company, subsidiaries, and other entities when providing the disclosure
throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or
entities are conducting the business operations. Refrain from using terms such as “we” or “our” when
describing activities or functions of a subsidiary or other entity. For example, disclose, if true, that your subsidiaries and/or
other entities conduct operations in China, that the other entity is consolidated for accounting purposes but is not an entity in
which you own equity, and that the holding company does not conduct operations. Disclose clearly the entity (including the domicile)
in which investors are purchasing an interest.

SIPP
International Industries, Inc is the holding company located in Nevada and controls 100% shares of Chengzhao International Holdings Ltd.
(CIHL), a BVI company. This is referred to as “SIPN” or “the Company” in the Amendment. SIPN is the entity in
which investors are purchasing an interest.

Chengzhao
International Holdings Ltd. (CIHL), a BVI company, is a holding company subsidiary of SIPN, which controls 100% shares of Sichuan Ruichengyuan
Agricultural and Sideline Products Distribution Co., Ltd. CIHL doesn’t conduct any business operations. It is referred to as “CIHL”
in the Amendment.

Sichuan
Ruichengyuan Agricultural and Sideline Products Distribution Co., Ltd (“SRAS”), is a Chinese company and a subsidiary of
CIHL. SRAS is conducting business operations in China. It is referred to as “SRAS” in the Amendment.

    2

We
have removed the references to “we” and “our” where appropriate.

4.
Provide a description of how cash is transferred through your organization and disclose your intentions to distribute earnings or settle
amounts owed under the applicable agreements. State whether any transfers, dividends, or distributions have been made to date between
the holding company, its subsidiaries, and consolidated entities, or to investors, and quantify the amounts where applicable.

While
this information was previous included on the cover page, we have expanded the disclosure to clarify the above.

5.
Please reconcile the disclosure on the cover page that your officers and directors are “based in China” with the information
about your mailing address on page 45 and the addresses of your officers and directors in Australia and New Zealand on page 48 of this
document. If your officers and directors are located in China, then revise the disclosure to identify the officers and directors located
in China. Also, expand the Business section beginning on page 41 to include a section to provide the disclosure required by Item 101(g)
of Regulation S-K.

Min
Jiang is based in China. Her mailing address is No. 1201, Floor 12, Unit 1, Building 1, No. 39, Zhiyuan Road, Wenjiang District, Chengdu,
China. Zonghan Wu is based in New Zealand.

We
have added disclosure to the Business section to added the enforceability of civil liabilities.

6.
Please revise the cover page and the summary to disclose, if applicable, that Min Jiang has sufficient voting power through the ownership
of common stock to control or substantially influence the vote on substantially all corporate matters. In this regard, we note the disclosure
in the table on page 48.

We
have revised the cover page and the summary to include the applicable disclosure.

Prospectus
Summary, page 1

7.
Please include a summary of risk factors that discloses the risks that your corporate structure and being based in or having the majority
of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement
risks with cross-references to the more detailed discussion of these risks in the prospectus. For example, specifically discuss risks
arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations
in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations
at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could
result in a material change in your operations and/or the value of the securities you are registering for sale. Acknowledge any risks
that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

We
have added the additional disclosure in the Prospectus Summary in the Amendment.

    3

8.
Disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business
and to offer the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions
requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental
agency that is required to approve your or your subsidiaries’ operations, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to
you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you
are required to obtain such permissions or approvals in the future.

We
have added such disclosure to the Prospectus Summary.

9.
Provide a clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings or
settle amounts owed under your operating structure. Quantify any cash flows and transfers of other assets by type that have occurred
between the holding company, and its subsidiaries, and direction of transfer. Quantify any dividends or distributions that a subsidiary
has made to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear if no transfers, dividends, or distributions
have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders,
and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your
subsidiaries to the parent company and U.S. investors as well as the ability to settle amounts owed under the applicable agreements.

We
have added this disclosure to the Prospectus Summary.

    4

10.
Disclose that trading in your securities may be prohibited under the Holding Foreign Companies Accountable Act, as amended by the Consolidated
Appropriations Act, 2023, and related regulations if the PCAOB determines that it cannot inspect or investigate completely your auditor
for a period of two consecutive years, and that as a result an exchange may determine to delist your securities.

We
have added this Disclosure to the Prospectus Summary.

Corporate
History, page 1

11.
Please clarify the relationship, if any, between David Lazar and the public companies mentioned on page 44.

We
have added disclosure related to Mr. Lazar’s relationships to a couple of the companies listed.

12.
Please disclose the period of time when the registrant was a shell company. In this regard, we note the information in the company’s
public document dated March 8, 2023 that the company “was previously as (sic) shell company, until November 1, 2022, as the Company
was dormant and had no or little operations.” Also, clarify the disclosure about the status of the company’s operations until November
1, 2022. For example, we note the disclosure on page 38 that “Our Company has been dormant since 2007” and the disclosure on
page F-8 that “The company ceased operations in 2014.”

We
have clarified the time frame of the company being a shell company.

Competitive
Strengths, page 4

13.
Please revise the disclosure on pages 4 and 41 to clearly explain the company’s competitive strengths and growth plan. For example,
clarify what you mean by the references to “traceable source procurement” and the “consumer business ecological
closed loop.” Also, discuss in greater detail the relationship with the “professional brand operation and management
company” and the “brand management company” mentioned on pages 4 and 41, such as whether there are written agreements
with the company and, if applicable, the material terms of the agreement.

We
have added disclosure to the Amendment, further detailing and describing out competitive strengths.

Growth
Plan, page 4

14.
Please disclose the amount of funds needed to fund the growth plan mentioned in this section and the source of the funds. Also, disclose
in this section and the Use of Proceeds section the amount of proceeds from this offering to be used for the growth plan discussed on
page 4.

We
have added disclosure regarding the amount of funds needed from this offering to meet our growth plan and the Company’s plans if
such amount is not raised. We have also updated the Use of Proceeds to detail the funds being used for such growth plan.

    5

15.
Please revise the disclosure in this section to consistently refer to the number of restaurants and the timeframe. In this regard, we
note the references on page 4 to “100 chain restaurants will be opened in 2023-2026” and “the overall chain restaurant
scale in the country could reach 200” in 2023 - 2025. Also, revise the disclosure in this section to clarify the difference between
“robot restaurants” and “chain restaurants.”

We
have revised the disclosure to consistently disclose the growth plan and clarify the descriptions.

Risk
Factors, page 10

16.
We note the disclosure in the risk factors on pages 11 and 13 about internal controls over financial reporting and disclosure controls
and procedures. Please include a risk factor to highlight the risks mentioned on page 38, such as the conclusion that your disclosure
controls and procedures were not effective and the material weaknesses identified by your CEO and CFO. Also, revise the disclosure on
page 44 to identify your CFO.

We
have added the requested risk factor and clarified that Min Jiang is also acting as our CFO.

Our
success depends on our personnel, page 12

17.
Please reconcile the reference on page 12 and elsewhere in your filing to “Zonghan Wu” with the references on page F-15 to
“Zhonghan Wu.”

We
have reconciled the references throughout the Amendment.

Risks
Related to Doing Business in China, page 17

18.
We note your disclosure about the Holding Foreign Companies Accountable Act. Please expand your risk factors to disclose that the Holding
Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, decreases the number of consecutive “non-inspection
years” from three years to two years, and thus, reduces the time before your securities may be prohibited from trading or delisted.
Update your disclosure to describe the potential consequences to you if the PRC adopts positions at any time in the future that would
prevent the PCAOB from continuing to inspect or investigate completely accounting firms headquartered in mainland China or Hong Kong.

We
have updated the risk factor to include the reduction in inspection years and potential consequences.

    6

19.
Given the Chinese government’s significant oversight and discretion over the conduct of your business, please revise to highlight
separately the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of the securities you are registering. Also, given recent statements by the Chinese government
indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based
issuers, acknowledge the risk that any such action could significantly limit or completely hinder your ability to offer or continue to
offer securities to investors and cause the value of such securities to significantly decline or be worthless.

We
have added a separate risk factor highlighting the above.

20.
In light of recent events indicating greater oversight by the Cyberspace Administra