SecProbe.io

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                                                              February 8, 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
                  Suzanne Hayes, Esq.
                  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 8, 2005 relating to the Registration Statement (the "Registration
Statement") on Form SB-2 of China Health Holding, Inc. (the "Company").

     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"). In connection with the FDA Disclosure,
the Staff has requested that the Company include a statement as to whether the
Company has determined that the herbs contained in its products are on one of
the FDA's list of problem herbs.

     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 8, 2005
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     products appeared on the 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. We have not determined
     whether any of the herbs in our products are on the FDA's list of problem
     herbs and we have not determined whether any such herbs are Generally
     Recognized as Safe. If any of the herbs in our products 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 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. We have not determined
     whether any of the herbs in our products are on the FDA's list of problem
     herbs and we have not determined whether any such herbs are Generally
     Recognized as Safe. 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.

     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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