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May 17, 2023
Jennifer Zhan
Chief Executive Officer
SHINECO, INC.
Room 1001, Building T5, DaZu Square
Daxing District, Beijing
People’s Republic of China
Re:SHINECO, INC.
Form 10-K for Fiscal Year Ended June 30, 2022
File No. 001-37776
Dear Jennifer Zhan:
            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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended June 30, 2022
Consolidation of Variable Interest Entities, page 23
1.We note that the consolidated VIEs constitute a material part of your consolidated
financial statements.  Please provide in tabular form a condensed consolidating schedule
that disaggregates the operations and depicts the financial position, cash flows, and results
of operations as of the same dates and for the same periods for which audited consolidated
financial statements are required.  The schedule should present major line items, such as
revenue and cost of goods/services, and subtotals and disaggregated intercompany
amounts, such as separate line items for intercompany receivables and investment in
subsidiary.  The schedule should also disaggregate the parent company, the VIEs and its
consolidated subsidiaries, the WFOEs that are the primary beneficiary of the VIEs, and an
aggregation of other entities that are consolidated.  The objective of this disclosure is to
allow an investor to evaluate the nature of assets held by, and the operations of, entities
apart from the VIE, as well as the nature and amounts associated with intercompany

 FirstName LastNameJennifer Zhan
 Comapany NameSHINECO, INC.
 May 17, 2023 Page 2
 FirstName LastNameJennifer Zhan
SHINECO, INC.
May 17, 2023
Page 2
transactions.  Any intercompany amounts should be presented on a gross basis and when
necessary, additional disclosure about such amounts should be included in order to make
the information presented not misleading.
Note 3 - Summary of Significant Accounting Policies
Consolidation of Variable Interest Entities, page F-12
2.Pursuant to ASC 810-10-50-3 please disclose the following:
•Please provide qualitative information about the relationships between the
VIE's assets and liabilities that are consolidated.  For example, if the VIE's assets can
be used only to settle obligations of the VIE, please disclose qualitative information
about the nature of the restrictions on those assets;
•Please address whether creditors or beneficial interest holders of the VIE have no
recourse to the general credit of the primary beneficiary; and
•Please disclose the terms of any arrangements, if applicable, that could require you to
provide financial support.
3.Pursuant to ASC 810-10-45, please present each of the following separately on the face of
the statement of financial position:
•Assets of a consolidated VIEs that can be used only to settle obligations of the
consolidated VIE; and
•Liabilities of a consolidated VIE for which creditors or beneficial interest holders do
not have recourse to the general credit of the primary beneficiary.
Note 20 - Commitments and Contingencies
Legal Contingencies, page F-36
4.If it is reasonably possible that a loss or an additional loss in excess of the amount accrued
may have been incurred, please disclose an estimated range; otherwise, provide a
statement that such an estimate of the possible loss or range of loss cannot be made, if
true.  Refer to ASC 450-20-50-3 and 50-4.
General
5.Please conform the disclosures in your Form 10-K, related to your operations in China,
with the disclosures in your amended Form S-3 (File No. 333-261229), taking into
consideration comments 1 to 16 from our letter dated November 29, 2021 and
comment 1 from our letter dated May 20, 2022, as applicable. Disclosures presented in the
forepart/prospectus of Form S-3 should be disclosed at the onset of Item 1. Business in
your Form 10-K. Please confirm your understanding of this matter and that you will
comply with the requisite disclosures in your Form 10-K, as applicable, in your response
to us.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameJennifer Zhan
 Comapany NameSHINECO, INC.
 May 17, 2023 Page 3
 FirstName LastName
Jennifer Zhan
SHINECO, INC.
May 17, 2023
Page 3
            You may contact Nudrat Salik at 202-551-3692 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jessica Ansart at 202-551-4511 or Celeste Murphy at 202-551-3257 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       David Manno