SecProbe.io

July 28, 201 5

Yuying Zhang
Chief Executive Officer
Shineco, Inc.
Room 3106, Building B
#39 East 3rd Ring Middle Road
Chaoyang District
Beijing 100022
People’s Republic of China

Re: Shineco, Inc.
Amendment No. 1 to
Registration Statement on Form S -1
Filed July 1 , 201 5
File No. 333 -202803

Dear Mr. Zhang :

We have reviewed your amended registration statement  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 by amending your registration statement and
providing the requested information .  If you do not believe our comments apply to your
facts and circumstances or do not believe an amen dment is appropriate, please tell us why
in your response.

After reviewing any amendment to your registration statement and the
information you provide in response to these  comments, we may have additional
comments.   Unless we note otherwise, our refere nces to prior comments are to comments
in our March 27, 2015 letter .

Registration Fee Table

1. We note your response to our prior comment 2 that you are registering the NMS
warrants.  However, these warrants do not appear to be reflected in the fee table .
The warrants in the fee table are listed  as the Placement Agent Warrants, which
appears to refer to the  warrants being issued to your placement agent.  Please
revise or advise.

Yuying Zhang
Shineco, Inc.
July 28, 2015
Page 2

Prospectus cover page

2. We note your response to our prior comment 3  and reissue the comment .
Although you indicate that  if the minimum amount is not sold , the offering will
end on October 31, 2015 , the language “ subject to extension upon agr eement with
the placement agent ” suggests that  you and your placement agent have discretion
to indefinitely hold the offering open .  Please note that Rule 10b -9(a)(2) requires a
specified time period and date.   Any possible extension should also indicate a date
or certain amount of days, for instance.

Risk Factors, page 9

3. To the exte nt material to understanding your business and your dependence on a
particular customer, please provide appropriate risk factor disclosure about any
customer concentration risk.  Additionally please provide us with your analysis as
to whether your agreemen ts with these customers should be filed as exhibits.  In
this regard we note the disclosure under “Concentration and Risks” on pages F -23
and F -21.

4. Please identify any suppliers upo n which you are dependent and provide
appropriate risk factor disclosure o r tell us why you believe the identity of the
supplier is not material to an understanding of your business.  In addition to the
extent any supplier agreements are material to you, please file  such agreements as
exhibits to your next amendment or please te ll us why this is not required.  In this
regard we note the disclosure under “Concentration and Risks” on pages F -23 and
F-21.

Proposed legislation in the PRC could adversely affect our corporate structure, page 12

5. We note your response to our prior comment 1.   We note the disclosure on page
12 that “[t] he Discussion Draft is aimed to replace, upon its enactment, existing
laws regulating foreign investments in China with a uniform law and, if adopted,
could affect a wide range of foreign entities, including our Company, and
investments generally in Ch ina” and similar disclosure on page 21.  Please briefly
expand to explain what the changes to existing law may be, if the Discussion
Draft is adopted in its current form, and how those changes may impac t your VIE
structure, so investors may assess the risk.

Executive Compensation, page 86

6. Please revise to provide disclosure as of the most recently completed fiscal year.

Yuying Zhang
Shineco, Inc.
July 28, 2015
Page 3

You may contact Aamira Chaudhry at (202) 551 - 3389 or Lynwood Shenk at
(202)  551- 3380 if you have questions regarding comments on the financial statements
and related matters.  Please contact John Dana Brown at (202) 551 -3859 or me at (202)
551-3210 with any other questions.

        Sincerely,

        /s/ Susan Block

Susan Block
Attorney Advi sor

cc: Anthony W. Basch, Esq.
Kaufman & Canoles, P.C.