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Hebron
Technology Co., Ltd. s
No. 587 15th Road, 3rd Av., Binhai Ind. Park s

Economic
& Technology Development Zone s
Wenzhou, Zhejiang Province s
China s +86-0577-8689-5678

December 16, 2015

Pamela A. Long, Assistant Director

Division of Corporation Finance

U.S. Securities and Exchange Commission

Mail Stop 3561

100 F Street, N.E.

Washington, D.C. 20549-4631

 Re: Hebron Technology Co., Ltd.

SEC comment letter dated July 13, 2015
about Amendment No. 1 to Draft Registration Statement on Form F-1

CIK No.: 0001603993

Dear Ms. Long:

On behalf of Hebron Technology Co., Ltd. (the “Registrant”,
“Hebron Technology” or the “Company”) and in response to the comments set forth in your letter dated July
13, 2015, we are writing to supply additional information and to indicate the changes that have been made in the enclosed Registration
Statement on Form F-1 (the “Registration Statement”). Capitalized terms used herein shall have the meanings ascribed
to them in the Registration Statement unless otherwise defined herein. We have also enclosed five redlined copies of the Registration
Statement compared against the first amendment to the draft registration statement confidentially submitted on June 22, 2015 for
your review (the “DRS”).

Use of Proceeds, page 27

    1.
    We note your response to comment 21 of our letter dated April 24, 2014.  Please expand your disclosures to clarify how you will use the net proceeds of this offering to expand installation services and establish online store of products and services.  Please also refer to the disclosures specified in Item 3C to the Form 20-F, including if proceeds are being used directly or indirectly to acquire assets.

We have revised the Registration Statement to clarify the manner
in which we will use the net proceeds of the offering to expand our installation services and establish an online store of products
and services. We currently do not have any plans to use the proceeds of this offering directly or indirectly to acquire assets.
The revised disclosure may be found on page 27 and reads as follows:

 (1) We
started our repair and maintenance service business in 2015. We provide pharmaceutical manufacturers repair and maintenance services
after the expiration of their product and installation service warranties. We have established a repair and maintenance center
in Nanjing, Jiangsu Province to cover Eastern China (Jiangsu Province, Zhejiang Province, Anhui Province and Shanghai) with an
investment of RMB 2,452,684 (approximately $400,000). Over the next 3 years, we plan to use a portion of the net proceeds of this
offering to establish five additional repair and maintenance centers in Shanghai, Beijing, Nanjing, Chengdu and Linyi respectively
to cover Central China, Northeastern China, Northern China, Southern China, and Northwestern China, with Shanghai being the center.
We anticipate that the proceeds of this offering will be sufficient to fund these new centers. To the extend we raise proceeds
upon maximum offering, we would further devote more proceeds to increase the size and scope of each repair and maintenance center.

Pamela A. Long, Assistant Director

December 16, 2015

Page 2

 (2) We
anticipate using a portion of this offering to settle taxes due for the company. The amount of taxes due is not presently determinable,
and may exceed the amount allocated to this item. To the extent this is the case, we anticipate using operating cash flows from
the company to cover such shortfall. However we cannot guarantee that such operating cash flows will be available. (See “Risk
Factors - We may incur liability for unpaid taxes, including interest and penalties.” and “Risk Factors - We have
broad discretion in the use of the net proceeds from our initial public offering and may not use them effectively.”)

In order to grow our installation services business,
we need to be able to perform more projects at the same time. Due to limited unrestricted cash to pay for advances to subcontractors
in different projects, we are generally limited to two projects at the same time. With the proceeds from this offering, we will
aim to conduct two to four more projects simultaneously. As the capacity to perform more projects at the same time increases, we
plan to add three more branch offices with six new employees for sales or technology support to each new office to guarantee our
services to clients. We expect the new branch offices will be located in Linyi in Shandong Province, Chengdu in Sichuan Province
and Nanjing in Jiangsu Province (in addition to the current one in Nanjing) respectively. We currently do not have any plans to
expand our installation services through acquiring any assets or businesses.

In addition, we intend to establish an online store
for our products and services with the net proceeds from this offering. With help from an unrelated third-party web design and
maintenance company, we will establish our own online store in the form of a Business-to-Business platform. We will also develop
our own operation administration, internet technology team, online store maintenance offices, product storage, and logistic and
delivery center to provide our customers with online consulting, online ordering, delivery, installation, and after-sales service.
We plan to begin by building our online store team and facilities to conduct market research and analysis about online store operation.
When we complete our analysis, we will establish our actual online store of products and services. In the process, we will build
and maintain our platform website, test and promote the website and put it into daily operation. We will also provide initial consulting
services regarding our holistic production technique solution services for pharmaceutical engineering and food manufacturing systems.
We currently do not have any plans to use any third-party online stores as our platform for online service. Also, we do not currently
plan to establish our online store through acquiring any assets or businesses.

Pending use of the net proceeds, we intend to invest
our net proceeds in short-term, interest bearing, investment-grade obligations. These investments may have a material adverse effect
on the U.S. federal income tax consequences of an investment in our common shares. It is possible that we may become a passive
foreign investment company for U.S. federal income taxpayers, which could result in negative tax consequences to you. These consequences
are discussed in more detail in “Taxation.”

Corporate Information, page 45

    2.
    Throughout this section, please clarify the nature of your services and markets for your services and products.  On page 45, you identify medicine, biology, food and beverage as the areas in which you provide services and products.  We assume that “medicine” refers to the pharmaceuticals that you discuss elsewhere, but please clarify.  Please also elaborate on how your products and services are used in these areas, and whether your products or services are specially designed to service these areas, or if these are simply the business that your customers happen to be in.

We acknowledge the comment and have revised the Registration
Statement to clarify the nature of services and markets for our services and products. We have revised the term “medicine”
to “pharmaceuticals” to refer to pharmaceutical products. We have further clarified that we provide services of designing
and implementing solutions that can be put to use in a variety of industries. Our products and services are not generally limited
to specific industries; instead, we provide services and products in multiple industries that are fluid-based. Thus, for example,
our systems can be used in various food, beverage and pharmaceutical companies, because they rely on the throughput and processing
of fluid products.

From the beginning of 2013 through the date of this filing,
we have performed 19 service projects for customers in different industries including the cosmetics, dairy, pharmaceutical, beverage,
chemical and water purification industries. The services we have provided to these customers include technological piping system
installations. Generally speaking, we design the layout of the project according to the need of the customer, and we help the customer
to install the equipment it purchases. Customers sometimes purchase pipes, valves, pumps, pipe fittings and other products produced
by us directly for our service projects. We not only install the equipment, but also coordinate the electricity, water and other
utilities subcontractors involved to make sure the whole system is completely ready to use for the customer.

Pamela A. Long, Assistant Director

December 16, 2015

Page 3

The process to the projects in different industries are similar,
the differences lie in the standard of project acceptance, sanitary requirement of products, installation precision, certain application
requirements and the specific components used in the installation. For example, the pharmaceutical industry requires installation
services with high precision to produce sanitary products, and it requires application for Good Manufacturing Practice (“GMP”)
certification from China’s State Food and Drug Administration. In this case, we would perform our service according to specific
pharmaceutical standards and provide paper records or related documents regarding the installation process to assist our customers
in applying for GMP certification. Other industries may not need to apply for GMP certification and technical tolerances may not
be as specific as in pharmaceutical industry.

    3.
    We also note disclosure on page 48 that you provide services to pharmaceutical companies as well as companies in the semi-conductor and electronic industries.  If material, please include these in your discussion of the markets for your products and services.

We acknowledge the comment and respectfully advise the Staff
that we have not yet provided any services to the companies in the semi-conductor or electronic industries and have no near-term
plans to do so. Instead, the disclosure we made on page 48 of the DRS indicated our ability to provide services to companies in
the semi-conductor, electronic and other clean industries. These industries are our target markets rather than actual customers.
The services we could provide to the companies in the semi-conductor and electronic industries are similar to the ones we provide
to the companies in the pharmaceutical industry as they both involve processing fluid products. We have revised the Registration
Statement to clarify our disclosure. The revised disclosure may be found on page 48 and reads as follows:

We specialize in installing valves and pipes for customers
that require customized fluid control system solutions. We also specialize in designing and implementing solutions for industries
with a high need for sanitary fluid systems. Currently, we have customers for our services in the industries of pharmaceuticals,
dairy products, water purification, beverage production, cosmetics and chemical industry. We hope to expand our customer base in
the future to the semi-conductor, electronic and other clean industries. Due to the requirements in these industries to avoid contamination,
we focus on designing systems that may be easily and frequently cleaned and maintained. We use skilled workers to install these
systems. Because the scope of a given project can be relatively large, our revenues per installation project tend to be much higher
than the average product-only order; accordingly, installation services make up the largest component of our revenues. Revenues
from installation services were approximately 87%, 84%, 73% and 94% of our total revenues for the six months ended June 30, 2015
and for the years ended December 31, 2014, 2013 and 2012, respectively.

    4.
    On page 48 and elsewhere in the “Corporate Information” section and MD&A, you refer to the “pharmaceutical engineering sector” or “pharmaceutical engineering construction.” Please explain the meaning of these terms and how your products and services are used.

We respectfully advise the Staff that “pharmaceutical
engineering” is a branch of pharmaceutical science and technology that involves development and manufacturing of products,
processes, and components in the pharmaceuticals industry, such as drugs and biologics. “Pharmaceutical engineering sector”
or “pharmaceutical engineering construction” refers to the related sector and construction.

Currently, most of our fluid equipment products and services
are provided to companies in pharmaceutical industry that fall in pharmaceutical engineering sector, and they play an important
role in the pharmaceutical engineering construction. Some of our products are used in pharmaceutical engineering construction or
maintenance by us or other third parties. We also provide holistic pharmaceutical engineering solution services which combine with
product manufacture, installation services and after-sales services.

Pamela A. Long, Assistant Director

December 16, 2015

Page 4

We have added our disclosure to clarify the meaning of “pharmaceutical
engineering”. The added disclosure may be found on page 2 and reads as follows:

“Pharmaceutical engineering” is a branch
of pharmaceutical science and technology that involves development and manufacturing of products, processes, and components in
the pharmaceuticals industry, such as drugs and biologics.

We have also added our disclosure to clarify how “pharmaceutical
engineering” relates to our products and services. The added disclosure may be found on page 3 and reads as follows:

Currently, a significant portion of our fluid equipment
products and services are provided to pharmaceutical companies for pharmaceutical engineering construction or maintenance. We also
provide holistic pharmaceutical engineering solution services which combine product manufacturing, installation and after-sales
service. When we receive an order for technological piping system installation services from pharmaceutical companies, we design
the layout of the project according to their needs and provide them with recommendations for equipment to purchase. Once they agree
with the design and purchase the appropriate equipment, we install the equipment for them. We produce multiple products for the
pharmaceutical industry and many of our customers choose to use our products for the installation. In the course of installation,
we also retain subcontractors for electricity, water and other industries that are out of our service range to ensure that the
project is completed and ready to put into service. The pharmaceutical industry has specific sanitation requirements in the course
of installation, and our customers need to apply for Good Manufacturing Practice (“GMP”) certifications from China’s
State Food and Drug Administration, thus we perform our services accordingly to meet such pharmaceutical standards and issue paper
records or related documents regarding the installation process to assist our customers in applying for GMP certifications. After
installation, we provide after-sales service to promote our customers’ satisfaction towards our services and products.

The service processes for projects in different industries
are similar, with differences in the standard of project acceptance, sanitation requirement of products, installation precision,
certain application requirements and the specific components used in the installation.

New Products and Services, page 46

    5.
    We note several references throughout your prospectus to “intelligent” process control valves that you have developed.  Please explain what this means and how these valves are used.

We respectfully advise the Staff that intelligent process control
valve is a type of valve that can be controlled by software. P