SEC Comment Letter 0000000000-22-012273 to TANTECH HOLDINGS LTD (TANH)
TANTECH HOLDINGS LTD
Date: Nov. 10, 2022 · CIK: 0001588084 · Accession: 0000000000-22-012273
AI Filing Summary & Sentiment
File numbers found in text: 001-36885
Letter
United States securities and exchange commission logo November 10, 2022 Weilin Zhang Chief Financial Officer Tantech Holdings Ltd c/o Tantech Holdings (Lishui) Co., Ltd. No. 10 Cen Shan Road, Shuige Industrial Zone , Lishui City Zhejiang Province 323000 People’s Republic of China Re:Tantech Holdings Ltd Form 20-F for the Fiscal Year Ended December 31, 2021 Filed July 18, 2022 Response Dated October 12, 2022 File No. 001-36885 Dear Weilin Zhang: We have reviewed your October 12, 2022 response to our comment letter 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 12, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Permissions Required from the PRC Authorities for Our Operations, page 4 1.We note your response to our previous comment 3, specifically we note Company's analysis regarding who is subject to cybersecurity review by the Cyberspace Administration of China ("CAC"). We also note you conclude that "we don't believe we are not subject to the cybersecurity review by the CAC" while your analysis points to not being subject to review by the CAC. Please clarify whether you are or are not required to go through cybersecurity review by the CAC or otherwise advise.
FirstName LastNameWeilin Zhang Comapany NameTantech Holdings Ltd November 10, 2022 Page 2 FirstName LastName Weilin Zhang Tantech Holdings Ltd November 10, 2022 Page 2 Report of Independent Registered Public Accounting Firm, page F-2 2.Please refer to prior comment 7 and amend your filing to include the audited December 31, 2019 period as soon as practically possible. You may contact Lynn Dicker at (202) 551-3616 or Kevin Kuhar, Accounting Branch Chief, at (202) 551-3662 if you have questions regarding comments on the financial statements and related matters. Please contact Doris Stacey Gama at (202) 551-3188 or Jason Drory at (202) 551-8342 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
November 10, 2022
Weilin Zhang
Chief Financial Officer
Tantech Holdings Ltd
c/o Tantech Holdings (Lishui) Co., Ltd.
No. 10 Cen Shan Road, Shuige Industrial Zone , Lishui City
Zhejiang Province 323000
People’s Republic of China
Re:Tantech Holdings Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed July 18, 2022
Response Dated October 12, 2022
File No. 001-36885
Dear Weilin Zhang:
We have reviewed your October 12, 2022 response to our comment letter 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
September 12, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Permissions Required from the PRC Authorities for Our Operations, page 4
1.We note your response to our previous comment 3, specifically we note Company's
analysis regarding who is subject to cybersecurity review by the Cyberspace
Administration of China ("CAC"). We also note you conclude that "we don't believe we
are not subject to the cybersecurity review by the CAC" while your analysis points to not
being subject to review by the CAC. Please clarify whether you are or are not required to
go through cybersecurity review by the CAC or otherwise advise.
FirstName LastNameWeilin Zhang
Comapany NameTantech Holdings Ltd
November 10, 2022 Page 2
FirstName LastName
Weilin Zhang
Tantech Holdings Ltd
November 10, 2022
Page 2
Report of Independent Registered Public Accounting Firm, page F-2
2.Please refer to prior comment 7 and amend your filing to include the audited December
31, 2019 period as soon as practically possible.
You may contact Lynn Dicker at (202) 551-3616 or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 if you have questions regarding comments on the financial statements
and related matters. Please contact Doris Stacey Gama at (202) 551-3188 or Jason Drory at
(202) 551-8342 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services