SecProbe.io

July 27 , 201 6

Yuying Zhang
Chief Executive Officer
Shineco, Inc.
2nd Floor, Wanyuan Business Center
10 N Hongda Road
Daxing District, Beijing 100176
People’s Republic of China

Re: Shineco, Inc.
  Post-effective Amendment to Form  S-1
Filed  July 1 , 201 6
  File No.  333-202803

Dear Mr. Zhang :

We have reviewed your post -effective amendment 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 bel ieve an amendment 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.

General

1. You indicate on the cover page of the registration statement that the approximate date of
commencement of proposed sale to the public is “from time to time after the effective
date of this Registration Statement .”  Please note that you are not qualified to engage in a
delayed offering pursuant to Rule 415  with respect to the offering to the public .  Please
advise or revise accordingly.

Yuying Zhang
Shineco , Inc.
July 27 , 201 6
Page 2

 2. The Amendment to Escrow Deposit Agreement states that “the Company and Placement
Agent will provide all Subscribers to the Offering w ith the Supplement along with the
PPM and require those Subscribers who have invested in the Offering without first
receiving the Supplement to reconfirm his, her or its participation in the Offering or
withdraw from the Offering.”  As this language implie s subscribers may have already
invested in the offering, p lease tell us the amount of any funds you have received from
investors in this offering  to date .

3. The language referenced in the immediately preceding comment also indicates that you
are asking fo r reconfirmations from any investors who have previously invested in your
offering based on the prior offering documents.  Please explain how a reconfirmation
procedure is appropriate in light of the material changes in this offering, including the
reduced  price, reduced minimum and maximum, the extended termination date as well as
the presence of previous and written notice thereof, and the changes to the use of
proceeds.  In addition , if any funds have been received based on the prior offering
documents, please tell us whether any such funds have been promptly returned to
investors after July 1, 2016, and how your reconfirmation procedure conforms with
requirements of Rules 10b -9 and 15c2 -4.

4. We note from the cover page and page 7 that the NASDAQ Capital M arket approved the
application to list your common stock on April 28, 2016.  Please tell us if there is a time
limit with respect to this approval , and whether it  will remain in force until you issue
shares of common stock and listing begins.

5. Please tell us when you plan to price the offering and when you intend to disclose the
offering price.  The Amendment to Escrow Deposit Agreement suggest s that you have
already set the offering price at $4.50 per share , stating that “Each Share is being sold at a
price of $4.50 per Share.”   In addition, p lease tell us how you have complied with or
intend to comply with Rule 430A with respect to filing the information omitted pursuant
to that rule.

6. Please revise to disclose the status of the offering incl uding the amount of funds you have
received to date .

7. We note your statement on page 6 regarding the “assumed initial public offering price of
$4.50 per share of common stock, the midpoint of the range set forth on the cover page of
this prospectus.”  Howe ver, $4.50 is not the midpoint of the range of $4.00 and $6.00
stated on the cover page.  Please revise accordingly.

Executive Compensation, page 83

8. Please revise to include Executive Compensation disclosure for the year ended June 30,
2016.   Please tell us whether you are required to disclose the compensation of your CFO
Mr. Wang, or any other executive officers.

Yuying Zhang
Shineco , Inc.
July 27 , 201 6
Page 3

Where You Can Find More Information , page 104

9. Please revise the statement that you  “hereby incorporate by reference in this pr ospectus
all documents [you]  file pursuant to Sections 13(a), 13(c), 14 or 15(d) of the Exchange
Act before termination of this offering ” as it appears you are not eligible to incorporate
by reference.  In order to be eligible to incorporate by reference, General Instruction
VII.C to Form S -1 requires that the registrant “has filed an annual report required under
Section 13(a) or Section 15(d) of the Exchange Act for its most recently completed fiscal
year,” and you have not yet filed an annual report.

Undertakings, page II -7

10. Please revise to provide the undertakings required by Item 512(a) of Regulation S -K.

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 Act of 193 3 and
all applicable Securities  Act 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 the disc losures they have made.

Notwithstanding our comments, before we can declare the amended registration
statement effective, the company should provide us with a letter, acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Yuying Zhang
Shineco , Inc.
July 27 , 201 6
Page 4

 Please contact John Dana Brown  at (202) 551 -3859 or me a t (202) 551 -3611  with any
questions.

Sincerely,

 /s/ A.N. Parker

Anne Nguyen Parker
Assistant Director
 Office of Transportation and Leisure

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