SecProbe.io

December 2 7, 2013

Via E -mail
Mr. Yuan Huang
Chief Financial Officer
Joway Health Industries Group Inc.
No. 19, Baowang Road
Baodi Economic Development Zone
Tianjin, PRC  301800

Re: Joway Health Industries Group Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 20 12
 Filed April 1, 2013
 File No. 333-108715

Dear Mr. Huang :

We have reviewed your filing 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 providing the requested
information or by advising us when you will provide the requested response.  If you do not
believ e our comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10 -K for the Fiscal Year Ended Dece mber 31, 2012

Item 1A. Risk Factors, page 19
Risks Relating to Conducting Business in the PRC, page 23

1. As you disclose various restrictions relating to the conversion of currencies and
distribution of dividends in China, please tell us what consideration  you have given to
including “parent only” financial information in accordance with Rule 5 -04 of Regulation
S-X.

Mr. Yuan Huang
Joway Health Industries Group Inc.
December 27, 2013
Page 2

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page32

General

2. Please revise MD&A in future f ilings to clearly disclose and discuss the risks and
uncertainties surrounding management’s ability to consolidate Tianjin Joway Shengshi
Group Co., Ltd. via contractual arrangements.  Please clearly describe and discuss the
cash flows generated from these  arrangements, including their form (e.g., consulting fees)
and address any restrictions as the cash flows move through your subsidiaries to your
parent company.

Liquidity and Capital Resources, page 36

General

3. We refer to your risk factor on page 26, “Restrictions on currency exchange may limit
our ability to utilize our revenues effectively and the ability of our PRC Operati ng
Entities to obtain financing,” as well as the government regulations on dividend
distribution page 25, please expand your liqu idity disclosures in future filings to quantify
and discuss the restrictions on the ability of your VIE to make dividend payments to you
and/or to transfer funds outside of China.

Critical Accounting Policies – Basis of Consolidation, page 39

4. Please expand your disclosure in future filings to provide a comprehensive discussion of
management’s judgments regarding why your contractual arrangements allow you to
consolidate Tianjin Joway Shengshi Group Co., Ltd. despite the apparent control
prohibi tions under the laws of the PRC.

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 A ct 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 t he disclosures th ey have made.

In responding to our comments, please provi de 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 fr om taking any action with respect to the filing; and

Mr. Yuan Huang
Joway Health Industries Group Inc.
December 27, 2013
Page 3

 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.

You may contact Dale Welcome a t (202) 551 -3865 or Kevin Stertzel at (202) 551 -3723 if
you have questions regarding these comments.

Sincerely,

/s/ John Cash

John Cash
Accounting Branch Chief