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Aluminum
Corporation of China Limited

September 11,
2023

Via EDGAR

Mr. Kyle Wiley and Mr. Christopher
Dunham

Disclosure Review Program

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

United States of America

    Re:
    Aluminum Corporation of China Limited

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

    Filed April 25, 2023

    File No. 001-15264

Dear Mr. Wiley and Mr. Dunham:

This letter is in
response to the comment letter from the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities
and Exchange Commission (the “Commission”), dated August 4, 2023, relating to the Annual Report of Aluminum Corporation
of China Limited (“the Company”) on Form 20-F for the fiscal year ended December 31, 2022 (the “2022 Form 20-F”),
which was filed with the Commission on April 25, 2023. The Company expresses its appreciation to the Staff for taking the time to
review the 2022 Form 20-F, and for providing the helpful comments.

The Company has
filed today, via EDGAR, this letter with the Commission. The Company has responded, to the extent relevant, to each of the Staff’s
comments by providing responses in this letter, or providing an explanation if the Company has not fully responded to the comment.

To facilitate the
Staff’s review, we have included in this letter the caption and comment from the Staff’s comment letter in bold text and
have provided the Company’s response immediately following each comment. The page numbers in the responses refer to the page numbers
appearing on the bottom of 2022 Form 20-F.

    United
                                            States Securities and Exchange Commission

    Division of Corporation Finance

    Disclosure Review Program

    Mr. Kyle Wiley and Mr. Christopher
    Dunham

    -2-

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

Item 16I. Disclosure Regarding
Foreign Jurisdictions that Prevent Inspections, page 139

 1. We note your disclosures on pages iii,
                                            iv, vi, and 139. Please confirm, if true, that you are controlled by the State-owned Assets
                                            Supervision and Administration Commission of the State Council of China by virtue of the
                                            SASAC’s total ownership of your controlling shareholder. Please also briefly explain
                                            the State Council of China and the SASAC’s role as governmental entities.

Response:

The Company confirms that
the State-owned Assets Supervision and Administration Commission of the State Council of China (the “SASAC”) has controlling
financial interest in the Company by virtue of the SASAC’s 31.90% indirect equity ownership in the Company through Aluminum Corporation
of China (“Chinalco”), the Company’s controlling shareholder.

The State Council of China
is the executive body of the supreme organ of state power of the People's Republic of China. The SASAC is a special commission directly
under the State Council of China. Pursuant to the authorization of the State Council of China and in accordance with the Company Law
of the PRC, Law on State-owned Assets of the PRC and other relevant laws and administrative regulations, the SASAC is responsible for
exercising the functions and powers of an investor in central state-owned enterprises, including exercising economic and voting rights.
Except for exercising the functions and powers of an investor, the SASAC shall not interfere with the ordinary course operation of central
state-owned enterprises.

 2. We note that your principal subsidiaries
                                            provided in Note 1 to your consolidated financial statements indicates that you have a subsidiary
                                            in Hong Kong. Please note that Item 16I(b) requires that you provide disclosures for
                                            yourself and all of your consolidated foreign operating entities, including variable interest
                                            entities or similar structures.

 • With respect to (b)(2), please
                                            supplementally clarify the jurisdictions in which your consolidated foreign operating entities
                                            are organized or incorporated and provide the percentage of your shares or the shares of
                                            your consolidated operating entities owned by governmental entities in each foreign jurisdiction
                                            in which you have consolidated operating entities in your supplemental response.

    United
                                            States Securities and Exchange Commission

    Division of Corporation Finance

    Disclosure Review Program

    Mr. Kyle Wiley and Mr. Christopher
    Dunham

    -3-

 • With respect to (b)(3), (b)(4),
                                            and (b)(5), please provide the required information for you and all of your consolidated
                                            foreign operating entities in your supplemental response.

Response:

The Company respectfully
advises the Staff that the Company’s subsidiary in Hong Kong is not subject to the disclosure requirements under Item 16I(b). As
required by Item 16I of Form 20-F, “[an] identified foreign issuer that uses a variable-interest entity or any similar
structure that results in additional foreign entities being consolidated in the financial statements [emphasis added] of the registrant
is required to provide the [relevant] disclosures for itself and its consolidated foreign operating entity or entities.” The Company’s
Hong Kong subsidiary has been consolidated to the Company’s financial statements because it is wholly-owned by the Company through
shareholding, and not through variable-interest entity or any similar structure.

The Company further advises
that all the entities consolidated in the Company’s financial statements are owned by the Company through direct or indirect shareholding,
and the Company did not and does not have any variable-interest entity or similar structure that would result in additional foreign entities
being consolidated in its financial statements. Accordingly, the Company respectfully advises that only the Company, as the identified
foreign issuer, is subject to the disclosure requirements under Item 16I(b).

 3. Please supplementally describe
                                            the materials that were reviewed and tell us whether you relied upon any legal opinions or
                                            third party certifications such as affidavits as the basis for your disclosure under paragraphs
                                            (b)(2) and (3).

Response:

The Company respectfully
advises the Staff that Chinalco, the largest shareholder of the Company, directly and indirectly owned 31.90% of the Company’s
issued share capital, among which 29.43% was directly owned by the Company, and 2.47% was indirectly owned via its 100% owned entities
Baotou Aluminum Co., Ltd., Chinalco Asset Operation and Management Co., Ltd. and Aluminum Corporation of China Overseas Holdings
Limited. The Company confirmed Chinalco’s direct shareholding in the Company by reviewing the Company’s shareholder register,
and confirmed Chinalco’s indirect shareholding in the Company by reviewing the Company’s shareholder register and the shareholding
information of Baotou Aluminum Co., Ltd., Chinalco Asset Operation and Management Co., Ltd. and Aluminum Corporation of China
Overseas Holdings Limited, the latter of which is publicly available on the National Enterprises Credit Information Publicity System
of the PRC.

As advised by Jincheng Tongda &
Neal, the PRC counsel of the Company, Chinalco is the controlling shareholder of the Company under the Company Law of the PRC, by virtue
of its ability to exercise significant influence on the resolutions of the Company’s shareholders meeting even though it holds
less than 50% of the Company’s shares.

    United
                                            States Securities and Exchange Commission

    Division of Corporation Finance

    Disclosure Review Program

    Mr. Kyle Wiley and Mr. Christopher
    Dunham

    -4-

 4. We note your disclosure at page 139
                                            that eight of your directors are “members of the Chinese Communist Party.” Please
                                            further identify each “official” of the Chinese Communist Party as required by
                                            Item 16I(b)(4) of the Form 20-F.

Response:

The Company respectfully
advises the Staff that none of the Company’s directors who are members of the Chinese Communist Party is considered as an “official”
of the Chinese Communist Party because none of them held or is holding any official position in any governmental authority or public
institution. The Company further advises that Mr. Liu Jianping, former chairman and executive director of the Company, resigned
from all positions in the Company on July 19, 2023 due to work arrangement, as disclosed in the Form 6-K furnished to the Commission
by the Company on July 19, 2023.

 5. In order to clarify the scope
                                            of your review, please supplementally describe the steps you have taken to identify whether
                                            the members of your board or the boards of your consolidated foreign operating entities are
                                            officials of the Chinese Communist Party. 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.

Response:

The Company respectfully
advises the Staff that, with respect to the Company’s executive directors, the Company had reviewed (i) the questionnaire
completed by each executive director as part of the annual compliance procedures, and (ii) their official biography contained in
their “Dang’an” (referring to a permanent dossier or archival system that maintain certain official records
of citizens of mainland China) and record of their membership with the Chinese Communist Party maintained by the Company. These underlying
documents specify each of the Company’s executive director’s position, if any, in the committee(s) of the Chinese Communist
Party. With respect to the Company’s non-executive directors or independent non-executive directors, the Company had reviewed (i) the
questionnaire completed by each non-executive director or independent non-executive director as part of the annual compliance procedures
and (ii) the affidavit of each non-executive director or independent non-executive director. Based on such review, the Company noted
that no current director of the Company held or is holding any official position in any governmental authority or public institution.
Hence, our directors are not considered as officials of the Chinese Communist Party.

In addition, the Company
advises that, as submitted in the response to Question 2, the consolidated foreign operating entities of the Company are not subject
to the disclosure requirements under Item 16I(b).

    United
                                            States Securities and Exchange Commission

    Division of Corporation Finance

    Disclosure Review Program

    Mr. Kyle Wiley and Mr. Christopher
    Dunham

    -5-

 6. With respect to your disclosure
                                            pursuant to Item 16I(b)(5), please confirm that your Articles of Association contain one
                                            or more charters of the Chinese Communist Party, or the text of any such charters, and tell
                                            us the text of such charters. We also note that you have included language that such disclosure
                                            is “to our best knowledge.” Please supplementally confirm without qualification,
                                            if true, that your articles and the articles of your consolidated foreign operating entities
                                            do not contain wording from any charter of the Chinese Communist Party other than those outlined
                                            in your response.

Response:

The Company respectfully
advises the Staff that other than the provisions set forth in the table below, which either mentions the charter of the Chinese Communist
Party or adopts some text from the charter of the Chinese Communist Party, the current Articles of Association of the Company on Form 6-K
furnished to the SEC on June 20, 2023 does not contain wording from any charter of the Chinese Communist Party. The Company further
advises that, as submitted in the response to Question 2, the consolidated foreign operating entities of the Company are not subject
to the disclosure requirements under Item 16I(b).

    Articles
    Provisions

    1

    To safeguard the legitimate rights and interests of Aluminum Corporation
of China Limited (the “Company”), its shareholders and creditors, and to regulate the organization and activities of the
Company, the Company formulated the Articles of Association in accordance with laws and regulations such as the Company Law of the People’s
Republic of China (the “Company Law”), the Securities Law of the People’s Republic of China (the “Securities
Law”), the Constitution of the Communist Party of China (the “Party Constitution”), the Special Regulations of the
State Council on the Overseas Offer and Listing of Shares by Joint Stock Limited Companies (the “Special Regulations”), the
Mandatory Provisions for Articles of Association of Companies to be Listed Overseas, the Guidelines on Articles of Association of Listed
Companies, the Code of Corporate Governance for Listed Companies in China, the rules governing the listing of shares or securities
on the stock exchanges on which the Company’s Shares are listed (including the Shanghai Stock Exchange, The Stock Exchange of Hong
Kong Limited and the New York Stock Exchange) (the “Relevant Listing Rules”).

    12
    In accordance with the relevant regulations of the Party Constitution and the Company Law, organizations of the Communist Party of China (hereinafter the “Party”) shall be established; the Party Committee shall play the leadership role, providing direction, managing the overall situation and promoting implementation. The working organs of the Party shall be established, equipped with sufficient staff to deal with Party affairs and provided with sufficient funds to operate the Party organization.

    103
    The Company shall set up the Committee of the Communist Party of China of Aluminum Corporation of China Limited (the “Party Committee”), consisting of one secretary, one to two deputy secretary and several members. Eligible members of the Party Committee may serve as members of the Board of Directors, the Supervisory Committee and senior management through statutory procedures, while eligible Party members of the Board of Directors, the Supervisory Committee and senior management may also serve as members of the Party Committee pursuant to relevant provisions and procedures. Meanwhile, the Company shall also set up a disciplinary committee in accordance with the provisions, which shall consist of one secretary and