SecProbe.io

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                                                              February 7, 2005

VIA EDGAR AND FACSIMILE (202) 942-9533

Mail Stop 3-9
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

         Attn:    Jeffrey Riedler, Assistant Director
                  Zafar Hasan, Esq.
                  Ms. Dana Hartz
                  Ms. Lisa Vanjoske

         Re:      China Health Holding, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-119034

Ladies and Gentlemen:

     The following responses address the comment (the "Comment") of the
reviewing Staff of the Commission as discussed in a telephone conversation on
February 4, 2005 relating to the Registration Statement (the "Registration
Statement") on Form SB-2 of China Health Holding, Inc. (the "Company"). Today,
the Company also submitted supplemental responses to accounting comments of the
reviewing Staff as requested by the Staff on February 3, 2005. The Staff
suggested that they would provide one legal comment in a letter dated today's
date. Since no comment letter was received and in order to help expedite review
of the Registration Statement, we respond to the Comment on behalf of the
Company as follows.

     In Amendment No. 3 to the Registration Statement, the Company revised
certain disclosure as it relates to regulation by the Food and Drug
Administration (the "FDA Disclosure"). The Staff has requested that the Company
provide additional disclosure of risks to the Company's business as it relates
to the FDA Disclosure.

     In response to the Comment, the Company added the following disclosure
under the risk factor beginning "Compliance With Governmental Regulations May
Impose Additional Costs" on page 4 of the prospectus:

     Many of our dietary supplements contain traditional Chinese herbs which may
     or may not have been previously evaluated by the FDA. All herbs marketed in
     dietary supplements in the United States must be Generally Recognized as
     Safe (GRAS). The FDA maintains a list of problems herbs. If any of the
     herbs in our
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Securities and Exchange Commission
February 7, 2005
Page 2 of 3

     products appeared on FDA's list, or if the agency determined there were
     issues concerning their safety, we would not be able to market the products
     containing these ingredients in the United States. If any of such herbs
     have not been evaluated by the FDA and are not Generally Recognized as
     Safe, then we would not be permitted to sell products containing them in
     the United States. Any such prohibition could materially adversely affect
     our results of operations and financial condition.

     In response to the Comment, the Company added the following disclosure
after the second sentence of the first paragraph under "Research and
Development" in the "Plan of Operation" section:

     If approval of such products by the FDA or foreign regulators is delayed or
     cannot be obtained, we will be forced to delay our plans for producing the
     products for sale to consumers. While any delay could adversely affect our
     operations, we do not expect such a delay to be material since the great
     majority of our products are considered dietary supplements which generally
     do not require FDA or other regulatory approval.

The Company added similar disclosure to the description of each of the products
discussed under "Research and Development" in the "Plan of Operation" section.

     In response to the Comment, the Company revised the last paragraph on page
17 of the prospectus, immediately preceding the table of herbs which begins on
page 18, to read as follows:

          Our King of Herbs product line combines King of Herbs with other
     traditional herbs to produce the desired effect on the body. These herbs
     are mainly traditional Chinese herbs which may or may not have been
     previously evaluated by the FDA. All herbs marketed in dietary supplements
     in the United States must be Generally Recognized as Safe (GRAS). The FDA
     maintains a list of problems herbs. If any of the herbs in our products
     appeared on FDA's list, or if the agency determined there were issues
     concerning their safety, we would not be able to market the products
     containing these ingredients in the United States. If any of the below
     herbs have not been evaluated by the FDA and are not Generally Recognized
     as Safe, then we would not be permitted to sell products containing them in
     the United States. Any such prohibition could materially adversely affect
     our results of operations and financial condition. The following herbs used
     in Traditional Chinese Medicine are used in our product formulations.

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Securities and Exchange Commission
February 7, 2005
Page 3 of 3

     We trust that the foregoing appropriately addresses the issues raised by
your recent Comment Letter. Thank you in advance for your prompt review and
assistance.

                                                  Very truly yours,

                                                  /s/ David Schubauer
                                                  -------------------
                                                  David Schubauer
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