SecProbe.io

CORRESP
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Golenbock
Eiseman Assor Bell & Peskoe LLP

711 Third
Avenue, 17th Floor

New York,
New York 10017

(212)
212-907-7300

April 30, 2020

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

Attn: Irene Paik, Esq. and Joseph McCann, Esq.

 Re: Origin Agritech Limited.

Registration Statement on Form F-1

Filed on April 16, 2020

File No. 333-237712

Dear Ms. Paik and Mr. McCann:

Reference is made to the letter of the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated April 27, 2020. This
letter sets forth below the comments of that letter to the Registration Statement on Form F-1, File No. 333-237712 (“Registration
Statement”), of Origin Agritech Limited (the “Company”) filed on April 16, 2020, followed by the responses of
the Company. I am responding on behalf of the Company as its counsel.

Registration Statement on Form F-1, Filed April 16, 2020

General

 1. We note your Form 6-K filed March 10, 2020 indicating
that you received notice from the NASDAQ Stock Market that you had a capital deficiency under the continued listing rules of NASDAQ
and your press release dated April 15, 2020 indicating that you received RMB137.66 million from Beijing Changping Technology Innodevelop
Group (BC-TID) and entered into a definitive framework agreement with BC-TID. Please revise your prospectus to disclose these
events.

Response:

The Company has made the following updates
to the prospectus disclosure about the capital deficiency and the receipt of funds from BC-TID:

a) Page 5, in the introduction about the Company, revised and
additional language was added about the BC-TID arrangement and loan, and new disclosure was added about the NASDAQ capital deficiency
of the Company;

b) Page 23, a new risk factor about the NASDAQ capital deficiency
of the Company was added;

c) Page 32, in the business discussion, revised and additional
language was added about the BC-TID arrangement and loan; and

d) Page 49, in the MD&A, additional language was added about
the BC-TID arrangement and loan and the equity line of credit.

There was also added updated discussion
about the impact of the Covid-19 virus on the Company in the revised risk factor on page 17 and the addition of Covid-19 discussion
on page 48 in the MD&A.

There were other technical updating changes
to change certain references to an April 30 date from an April 16 date and updating changes to the exhibits index and signature
pages.

Based on the Financial Reporting Manual,
Topic 4 – Independent Accountant’s Involvement, Subpart 4810.3, the Company is not including accountant consents in
the Amendment No. 1 to the Registration Statement, as the two consenting accounting firms provided their respective consents for
the initial filing of the Registration Statement made on April 16, 2020, and since that date, which is less than 30 days prior
to the date of the filing of Amendment No. 1 to the Registration Statement, there has been no event that is material to the Company,
and no changes have been made to the financial statements or notes thereto included in the registration statement as initially
filed.

The Company has asked me to relay to the
Staff that it and its management understand that they are responsible for the accuracy and adequacy of the disclosures in the Registration
Statement, and the prospectus contained therein, notwithstanding any review, comments, actions, or absence of actions by the Staff.

Should you have any questions regarding
the foregoing or require any additional information, please do not hesitate to contact the undersigned at (212) 907-7349 or email
the undersigned at ahudders@golenbock.com. Thank you for your attention to this matter.

    Sincerely,

    /S/ Andrew D. Hudders

        Andrew D. Hudders,

 cc: Mr. James Chen, CFO of the Company