SecProbe.io

Mail Stop 4631
November 7, 2017

Via E -mail
Steven Fu
Chief Financial Officer
Hebron Technology Co., Ltd.
No. 936, Jinhai 2rd Road, Konggang New Area
Longwan District
Wenzhou City, Zhejiang Province
People’s Republic of China

Re: Hebron Technology Co., Ltd.
 Form 10-K for Fiscal Year Ended December 31, 2016
Filed April 11, 2017
File No. 1 -37829

Dear Mr. Fu :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 busine ss days b y providing the requested
information or advis e 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.

Item 3. Key Information, page 4
A. Selected Financial Data, page 4

1. Please provide all of the fiscal years required by Item 3.A. of Form 20 -F with consideration
of the guidance in the corresponding Instructi on 3.  In this regard, it would appear the earliest
fiscal year provided during your IPO process is 2011.  Please also ensure that you
appropriately characterize the amounts presented.  Specifically, the amounts do not appear to
be presented in thousands o f U.S. dollars.

Accounts and Contract Receivables, page 64

2. Based on your customer concentration disclosure on page 34, 96% of your contract
receivables are due from two major customers, who apparently have contract receivable
balances well in excess of t heir share of annual revenue.  Please provide further disclosure

Mr. Fu
Hebron Technology Co., Ltd.
November 7, 2017
Page 2

 describing how you considered these customers in determining no allowance was required on
contract receivables when applying ASC 310 -10-35.  Provide us with an analysis of the
amounts receiva ble, including the amount owed by each major customer as of December 31,
2016, the amount that has been collected since then, the original payment terms, the reasons
for deviation from original payment terms, and the reasons the application of the accounti ng
guidance does not result in impairment.

Consolidated Financial Statements, page F -1

3. Please amend your Form 20 -F to include three years of consolidated financial statements for
income and comprehensive income, changes in shareholders’ equity, and cash flows in
accordance with Item 17(a) of Form 20 -F, and by reference to Item 8(a) of Form 10 -K, and
Articles 3 -02(a) and 3 -04 of Regulation S -X.  In this regard, we note that the Form 20 -F is
your annual report rather than a registration statement.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Tracey Houser, Staff Accountant,  at (202) 551 -3736, or in her absence,
me at (202) 551 -3355, if you have questions regarding comments on the financial statements and
related matters.

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Accounting Branch Chief

Office of Manufacturing and
Construction