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CORRESP
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Room
3106, Building B s
#39 East 3rd Ring Middle Road s
Chaoyang District s

Beijing
100022 s People’s
Republic of China s
(+86) 105869-3011

    March 16, 2015

Susan Block, Attorney Advisor

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Shineco, Inc.

Amendment No. 1
to

Draft Registration
Statement on Form S-1

Submitted December
18, 2014

CIK No. 0001300734

Dear Ms. Block:

On behalf of Shineco, Inc.
(the “Registrant”) and in response to the comments set forth in your letter dated January 7, 2015, we are writing to
supply additional information and to indicate the changes that have been made in the enclosed Amendment No. 2 to the captioned
Draft Registration Statement (the “Amendment”). Factual information provided herein has been provided to us by Registrant.
Capitalized terms used herein shall have the meanings ascribed to them in the Registration Statement unless otherwise defined herein.
We have also enclosed one clean copy and two redlined copies of the Amendment for your review.

General

 1. The financial statements should be updated, as necessary, to comply with Rule 8-08 of Regulation S-X at the effective date
of the registration statement.

We acknowledge the comment and have revised the Registration
Statement to include updated financial statements that comply with Rule 8-08 of Regulation S-X.

Prospectus Cover Page

 2. We note your response to our prior comment 4 and reissue the comment. Please state the date the offering will end. Indicate
if there may be extensions to the offering and, if so, the duration of such extensions. Refer to Exchange Act Rule 10b-9 and Item
501(b)(8)(iii) of Regulation S-K.

We acknowledge the comment and have revised the Registration
Statement on the cover page with the language below that indicates a date the offering will end.

Susan Block, Attorney Advisor

March 16, 2015

Page 2

This offering will remain open until the earlier of: (i) a
date mutually acceptable to us and our placement agents after which at least $8,000,000 of our common stock is sold (the minimum
offering); (ii) such time as $10,000,000 of our common stock is sold (the maximum offering) or (iii) , 2015, subject to extension
upon agreement with the placement agents.

We have made similar revisions throughout the Registration
Statement indicating the date the offering will end.

Prospectus Summary, page 1

 3. We note your response to our prior comment 5. Please disclose that the McKinsey & Co. projection you cite was published
in 2012.

We acknowledge the comment and have revised the Registration
Statement to disclose that the McKinsey & Co. projection you cite was published in 2012. The new disclosure is found on page
1 and reads as follows:

In a report published in 2012, McKinsey & Co. projected
that China’s healthcare spending could grow to $1 trillion by 2020.

The Offering, page 6

 4. We note your response to our prior comments 6 and 7. From your response and your disclosure, it appears that the number
of placement agent warrants to be issued to the placement agent will be determined at the closing date, based on the results of
the best efforts offering and a percentage of common stock sold in the offering. We also note the aggregate offering price for
the placement agent warrants and underlying shares is currently blank in the fee table. Please provide us with your analysis regarding
how you can register that part of the transaction now, without indicating the amount of placement agent warrants, and the amount
of the underlying common stock. As part of your response, please tell us if the percentage will be determined prior to effectiveness.
We may have further comment when we review your response.

We acknowledge your comment. We have revised the registration
statement to include an updated fee table that includes the amount of placement agent warrants and the amount of underlying common
stock.

Risk Factors, page 9

 5. We note your response to our prior comment 16, including your disclosure that Yantai Agricultural “is a cooperative
and thus has no equity interests.” Please tell us what consideration you gave to providing risk factor disclosure explaining,
if true, that because this is a cooperative you are unable to control the actions of the cooperative members that control the cooperative,
or describe any other risks resulting from its structure as a cooperative. If there are no risks resulting from it being a cooperative
please explain to us why. In addition please tell us the difference between “Yantai Agricultural” which is referred
to only on page 29 and “Zhisheng Agricultural” which is referenced throughout the prospectus.

    2

Susan Block, Attorney Advisor

March 16, 2015

Page 3

We acknowledge the comment. The VIE agreements taken
together are designed to allow our Company to manage the operations of each of the Controlled Companies and to receive all of the
net income of such Controlled Companies in return therefor. To secure our interest in the Controlled Companies, the equity interest
pledge agreements (along with the exclusive option agreements and the powers of attorney) are designed to allow us to convert our
contractual interest into an equity interest in the event we determine that doing so is warranted. But the equity interest pledge
agreement is just one part of the guarantee of the performance of the VIE agreements by the parties thereto. In the case of Yantai
Agricultural where we do not have an equity pledge agreement (because it is a cooperative), if the domestic shareholders do not
comply with the terms of either of the exclusive business cooperation agreement or exclusive option agreement, Tenet-Jove, our
100% owned subsidiary, can sue for breach of contract. However, a substantially similar risk exists with respect to our other VIE
relationships; in short, the risk is one of a breach of contract, whether that be a breach of an equity interest pledge agreement
(when it is in place), a breach of the exclusive option agreement, or a breach of the exclusive business cooperation agreement.
We believe our current risk factor, “We rely on contractual arrangements with our variable interest entities in China for
our business operations, which may not be as effective in providing operational control or enabling us to derive economic benefits
as through ownership of controlling equity interests,” adequately expresses the risks with all our variable interest entities:
mainly, if any of the affiliated VIEs or any of their shareholders fails to perform its, his or her respective obligations under
the suite of agreements, we may have to incur substantial costs and resources to enforce such agreements, and rely on legal remedies
available under PRC laws, which remedies may not be effective.

We have revised the Registration Statement to remove
the mistaken references to Yantai Agricultural.

Related Party Transactions, page 75

 6. We note your response to our prior comment 27, and we reissue the comment. It appears that you may only be reporting transactions
that have occurred as of June 30, 2014. The disclosure in this section should not be limited to the end of the periods reported
in your financial statements. Please revise to disclose all reportable transactions as of the most recent practicable date or please
advise.

We acknowledge your comment and have revised the Registration
Statement to disclose all reportable transactions as of December 31, 2014. The new disclosure is found on page 83 and reads as
follows:

As of December 31, 2014, the Company temporarily advanced
a total of $567,342 to (i) Longevity Pharmaceutical Group Real Estate Co., Ltd., which is owned by our director Jiping Chen, (ii)
KuerLe Tenet-Jove Business & Trading Co., Ltd., which is owned by a family member of our Chief Executive Officer and director,
Yuying Zhang, (iii) Zhao Min, one of our shareholders, and (iv) Qiwei Wang, one of our shareholders.  All the advances were short-term loans for the requirements
of the related parties and were made interest-free.

    3

Susan Block, Attorney Advisor

March 16, 2015

Page 4

As of June 30, 2014, the Company temporarily advanced a total
of $1,361,513 to (i) Longevity Pharmaceutical Group Real Estate Co., Ltd., which is owned by our director Jiping Chen, (ii) KuerLe
Tenet-Jove Business & Trading Co., Ltd., which is owned by a family member of our Chief Executive Officer and director, Yuying
Zhang, (iii) Zhao Min, one of our shareholders, (iv) Qiwei Wang, one of our shareholders, and (v) Yantai Zhisheng International
Shipping Agent Co., Ltd. As of date of this report, all outstanding amounts due from those related parties have been collected.
All the advances were short-term loans for the requirements of the related parties and were made interest-free, and the balances
were settled in cash.

As of June 30, 2013, the Company had advanced a total of $5,429,021
to (i) Longevity Pharmaceutical Group Real Estate Co., Ltd., which is owned by our director Jiping Chen, (ii) KuerLe Tenet-Jove
Business & Trading Co., Ltd., which is owned by a family member of our Chief Executive Officer and Director, Yuying Zhang,
and (iii) Yantai Zhisheng International Shipping Agent Co., Ltd, which is owned by Qiwei Wang, one of our shareholders. As of June
30, 2014, the Company received the full payment of $5,429,021 from these three related party companies. All the advances were short-term
loans for the requirements of the related parties and were made interest-free, and the balances were settled in cash.

Description of Stock, page 78

 7. Please also add a description of the placement agent warrants here.

We acknowledge your comment and have included a description
of the placement agent warrants. The new disclosure is found on page 88 and reads as follows:

We have agreed to sell to the placement agents, on the closing
date of this offering, at a price of $0.001 per warrant, placement agent’s warrants exercisable at a rate of one warrant
per share to purchase 4% of the number of shares of common stock issued by us in connection with the offering. Such amount may
be reduced to no warrants for common stock sold to investors with whom we have a previous relationship. We will issue between 64,000
and 80,000 placement agent’s warrants in connection with this offering, depending on the number of shares of common stock
sold in this offering. Each placement agent’s warrant will be exercisable to purchase one share of common stock. The placement
agent’s warrants will be exercisable at 100% the offering price per share for a period of five years after issuance on the
closing date of this offering.

    4

Susan Block, Attorney Advisor

March 16, 2015

Page 5

Tax Matters Applicable to U.S Holders, page 82

 8. We note your response to our prior comment 28. Please revise to state what part of the disclosure in this section is the
opinion of Kaufman & Canoles, P.C.

We acknowledge the comment and have revised the Registration
Statement to state that nless otherwise noted, the disclosure in the “Tax Matters Applicable to U.S Holders” section
is the opinion of Kaufman & Canoles, P.C. insofar as it relates to legal conclusions with respect to matters of U.S. tax law.
The new disclosure is found on page 90 and reads as follows:

Unless otherwise noted in the following discussion, this section
is the opinion of Kaufman & Canoles, P.C., our U.S. counsel, insofar as it relates to legal conclusions with respect to matters
of U.S. federal income tax law.

United States Federal Income Taxation, page 84

Taxation of dividends and other distributions on our common
stock, page 84

 9. It appears that much of this disclosure is limited to “taxable years beginning before January 1, 2011.” We note
similar language “assuming the renewal of current capital gains rates prior to their scheduled expiration at the end of 2010”
on page 85. Please revise or advise.

We acknowledge the comment and have revised the Registration
Statement to correct mistaken disclosure. The new disclosure is found on page 93 and reads as follows:

With respect to non-corporate U.S. Holders, including individual
U.S. Holders, dividends will be taxed at the lower capital gains rate applicable to qualified dividend income, provided that (1)
the shares of common stock, are readily tradable on an established securities market in the United States, or we are eligible for
the benefits of an approved qualifying income tax treaty with the United States that includes an exchange of information program,
(2) we are not a passive foreign investment company (as discussed below) for either our taxable year in which the dividend is paid
or the preceding taxable year, and (3) certain holding period requirements are met. Under U.S. Internal Revenue Service authority,
shares of common stock are considered for purpose of clause (1) above to be readily tradable on an established securities market
in the United States if they are listed on the NASDAQ Capital Market. You are urged to consult your tax advisors regarding the
availability of the lower rate for dividends paid with respect to our shares of common stock, including the effects of any change
in law after the date of this prospectus.

    5

Susan Block, Attorney Advisor

March 16, 2015

Page 6

* * *

Subject to the passive foreign investment company rules discussed
below, you will recognize taxable gain or loss on any sale, exchange or other taxable disposition of a share equal to the difference
between the amount realized (in U.S. dollars) for the share and your tax basis (in U.S. dollars) in the shares of common stock.
The gain or loss will be capital gain or loss. If you are a non-corporate U.S. Holder, including an individual U.S. Holder, who
has held the shares of common stock for more than one year, you will be eligible for reduced tax rates of 0% (for individuals in
the 10% or 15% tax brackets) or 15% for all other individuals. The deductibility of capital losses is subject to limitations. Any
such gain or loss that you recognize will generally be treated as United States source income or loss for foreign tax credit limitation
purposes.

Index to Consolidated Financial Statements, page 93

 10. Please amend to include the report of your independent registered public accounting firm.

We
acknowledge your comment and have included the report of Friedman LLP, our  independent
registered public accounting firm.

Consolidated Statement of Cash Flows, page F-4

 11. Please tell us your basis for classifying “Loans to Third Parties” as operating cash flows. Please tell us what
consideration was given to presenting the loans as investing cash flows.

We acknowledge your comment and believe that “Loans
to Third Parties” should be included as investing cash flows instead of operating cash flows because we do generate interest
income on these loans. We have revised our Statements of Cash Flows accordingly to reflect such change.

Notes to the Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Fair Value of Financial Instruments, page F-10

 12. We note your response to our prior comment 30. You state that it was not practicable to estimate the fair value of your
investment in unconsolidated entities due to their lack of marketability. Please tell us how you determined that these investments
were not impaired and their value is recoverable.

    6

Susan Block, Attorney Advisor

March 16, 2015

Page 7

We
acknowledge your comment. We account for our investments in unconsolidated entities in which we hold a significant, but less than
controlling ownership interest, under the equity method of accounting. These investments are initially recorded at cost and thereafter
adjusted for additional investments, distributions and the proportionate share of earnings or losses of the investee. The fair
values of investments in unconsolidated enti