SecProbe.io

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      September 26, 2005

Via U.S. Mail

Julianna Lu
Chief Executive Officer
China Health Holdings, Inc.
666 Burrard St., Park Place,
Vancouver, British Columbia, Canada V6C 2X8

RE:		China Health Holdings, Inc.
		10-KSB for the Fiscal Year Ended December 31, 2004
		10-QSB for the Fiscal Quarter Ended June 30, 2005
		File No. 333-119034

Dear Ms. Lu:

      We have limited our review of your Form 10-KSB for the
fiscal
year ended December 31, 2004, and Form 10-QSB for the fiscal
quarter
ended June 30, 2005, to disclosures relating to your contacts with
countries that have been identified as state sponsors of
terrorism,
and will make no further review of the Form 10-KSB and Form 10-
QSB.
Our review with respect to this issue does not preclude further
review by the Assistant Director group with respect to other
issues.
At this juncture, we are asking you to provide us with
supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General -

We note that on page 9 of your 10-QSB filed August 15, 2005, for
the
quarterly period ended June 30, 2005, you state that you entered
into
two licensing agreements on March 9, 2004, with Hotway
Nutraceutical
Canada, Co. Ltd. The first agreement granted licenses to 19
cordyceps
products and the second agreement granted licenses to De-Daibe and
Depressor Herbs neutraceutical products.  Both agreements cover a
number of countries, including Iran.  In light of the fact that
Iran
has been identified by the U.S. State Department as a state
sponsor
of terrorism and is subject to economic sanctions administered by
the
U.S. Treasury Department`s Office of Foreign Assets Control,
please
describe for us the extent of your past, current and anticipated
contacts, directly or indirectly, with Iran; the materiality to
you
of your contacts, or intended contacts, with Iran; and your view
as
to whether those contacts constitute a material investment risk
for
your security holders.  In preparing your response please consider
that evaluations of materiality should not be based solely on
quantitative factors, but should include consideration of all
factors
that a reasonable investor would deem important in making an
investment decision, including the potential impact of corporate
activities upon a company`s reputation and share value.  In this
regard, we note that legislation requiring divestment from, or
reporting of interests in, companies that do business with
countries
designated as state sponsors of terrorism has recently been
adopted
by Arizona and Louisiana.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Jeffrey Riedler
		Assistant Director
		Division of Corporation Finance

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