SecProbe.io

October 20, 2011
 Via E-mail

Mr. Hen Man Edmund Chief Financial Officer China Ceramics Co., Ltd. c/o Jinjiang Hengda Ceramics Co., Ltd. Junbing Industrial Zone Anhai, Jinjiang City Fujian Province, PRC
RE: China Ceramics Co., Ltd.
Form 20-F for the Year ended Decemb er 31, 2010
Filed April 4, 2011
  File No. 1-34944

Dear Mr. Hen:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 20-F for the Year Ended December 31, 2010

 General

 1. Where a comment below requests additional disclosures or other revisions to be made, please
show us in your supplemental response what th e revisions will look lik e.  These revisions
should be included in your future filings.
 Item 4 – Information on the Company, page 21

 D. Property, Plant and Equipment, page 44

 2. You disclose that you collectively own six build ings in Jinjiang, Fujian Province with three
other companies.  Please tell us and revise your accounting policy disc losures to clarify how

Mr. Hen Man Edmund China Ceramics Co., Ltd. October 20, 2011 Page 2

 you are accounting for these properties.  In addition, disclose the amounts that you have
recorded related to these properties.
 Item 15 – Controls a nd Procedures, page 97

 Management’s Annual Report on Internal C ontrol over Financial Reporting, page 97

 3. Please revise your disclosure w ithin management’s re port on internal control over financial
reporting to present a statement of manage ment’s responsibility for establishing and
maintaining adequate internal c ontrol over financial reporting.  See Item 15(b)(1) of the Form
20-F requirements.
 Item 18 – Financial Statements, page 102

 Note 20 – Share Capital, page F-31

4. Please tell us and revise your disclosure s to clarify how you have accounted for the
contingent shares that were placed in escrow  and will be released in the event certain
earnings and stock price th resholds are achieved.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

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

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Mr. Hen Man Edmund China Ceramics Co., Ltd. October 20, 2011 Page 3

 You may contact Jeffrey Gor don, Staff Accountant, at (202)  551-3866 or, in his absence,
Jeanne Baker, Assistant Chief Accountant, at  (202) 551-3691 if you have questions regarding
these comments.        Sincerely,   /s/ Rufus Decker       Rufus Decker  Accounting Branch Chief  cc: Via E-mail

 Mr. Jaszick Maldonado  Loeb & Loeb LLP