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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

February 4, 2016

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 January 11,
2016 about Registration Statement on Form F-1

File No. 333-208583

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 January 11, 2016, we are writing to supply additional information and to indicate the changes that have been
made in the enclosed Pre-Effective Amendment 1 (the “First Amendment”) to our Registration Statement on Form F-1 filed
on December 16, 2015 (the “Registration Statement”). Capitalized terms used herein shall have the meanings ascribed
to them in the First Amendment unless otherwise defined herein. We have also enclosed five redlined copies of the First Amendment
compared against the Registration Statement for your review.

Our Services, page 48

 1. We note your disclosure that you hope to expand your customer base in the future to the semi-conductor, electronic, and other
clean industries. Please revise, consistent with your response to comment 3 of our letter dated July 13, 2015, that you have no
near term plans to provide services in any of these industries.

We acknowledge the comment and confirm that
we have no near-term plans to provide services in the semiconductor, electronic or other cleaning industries. Consistent with this
intent, we have revised the first paragraph on page 48 to read 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, but we have no near-term plans to provide services
in any of these 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.

Pamela A. Long, Assistant Director

February 4, 2016

Page 2

Executive Officers and Directors, page 64

 2. File as exhibits to the registration statement the consents of the six persons about to become directors. See Rule 438 of Regulation
C under the Securities Act.

On January 15, 2016, all the anticipated directors
(Steven Fu, Zuoqiao Sun Zhang, Xuesong Liu, Hua Zhang, Haiying Xiang and Xianpang Hu) have been appointed to be directors of the
Company in the meeting of Board of Directors. As a result, we have had each of such individuals sign a power of attorney rather
than the requested exhibit. The Power of Attorney may be found at page Part II - 6.

Summary Compensation Table, page 70; Director Compensation
– Fiscal 2014 and 2013, page 71; Director Compensation – Non-Employee Directors, page 71

 3. Update the disclosure to include compensation disclosure for the fiscal year ended December 31, 2015. See Items 4.a. of Form
F-1 and 6.B. of 20-F.

We have revised the disclosure in the Summary
Compensation Table and for the Director Compensation sections of the registration statement to reflect payments made in the year
ended December 31, 2015. The revised disclosure may be found on page 70 and reads as follows:

    Name and Principal Position

    Fiscal Year

    Salary ($)

    Bonus ($)

    Stock Awards ($)

    All Other Compensation

($)

    Total ($)

    Anyuan Sun

    2015

    32,109

    0

    0

    0

    32,109

    Chief Executive Officer

    2014

    32,544

    0

    0

    0

    32,544

    Steven Fu

    2015

    100,000

    0

    0

    0

    100,000

    Chief Financial Officer

    2014

    100,000

    0

    0

    0

    100,000

    Xiaoliang Xue

    2015

    19,265

    0

    0

    0

    19,265

    Chief Technical Officer

    2014

    19,526

    0

    0

    0

    19,526

Related Party Transactions, page 71

 4. Provide the information required for the period since the beginning of your preceding three financial years up to the date
of the prospectus. See Items 4.a. of Form F-1 and 7.B. of 20-F.

We have revised the Related Party Transaction
section to provide the requested information. The revised disclosure may be found on page 71 and reads as follows:

There are no related party transactions
during the period from January 1, 2016 up to February 4, 2016.

For the year ended December 31,
2015, Mr. Anyuan Sun, the Chairman of the Board and CEO of the Company, advanced a total of $920,660 to the Company for its working
capital purposes. The advance was due on demand and was non-interest bearing. The Company has fully repaid the balance as of December
31, 2015. As of each of December 31, 2015 and 2014, the Company had $Nil due to Mr. Anyuan Sun.

For the year ended December 31,
2014, the Company purchased $298,893 valve parts from its related party, Zhejiang Xibolun, an entity controlled by the same Controlling
Shareholder of the Company, Mr. Anyuan Sun, and sold $81,358 valves to Zhejiang Xibolun. As of December 31, 2015 and 2014, the
Company had $Nil due from related party – Zhejiang Xibolun.

As of December 31, 2013, we had
an aggregate of $280,160 due from related party, Zhejiang Xibolun. We fully repaid the balance due from Zhejiang Xibolun as of
December 31, 2014.

Pamela A. Long, Assistant Director

February 4, 2016

Page 3

Lock Up, page 92

 5. Describe briefly the factors that the placement agent would consider in determining whether to consent to the release of any
of the securities subject to the lock up agreement before its expiration period.

We have clarified that the placement agent
will not consent to the release of any of the securities subject to the lock up agreements before their expiration and have revised
the language on page 92 to reflect this fact. The revised language reads as follows:

Lock Up. We, on behalf of ourselves and any
successor entity, have agreed that, without the prior written consent of the Placement Agent, we will not,
for a period of one hundred eighty (180) days from the effective date of the Registration Statement (the “Lock-Up Period”),
(i) offer, pledge, sell, contract to sell, sell any option or contract to purchase, purchase any option or contract to sell, grant
any option, right or warrant to purchase, lend, or otherwise transfer or dispose of, directly or indirectly, any shares of capital
stock of our company or any securities convertible into or exercisable or exchangeable for shares of capital stock of our company;
(ii) file or caused to be filed any registration statement with the Commission relating to the offering of any shares of capital
stock of our company or any securities convertible into or exercisable or exchangeable for shares of capital stock of our company
or (iii) enter into any swap or other arrangement that transfers to another, in whole or in part, any of the economic consequences
of ownership of capital stock of our company, whether any such transaction described in clause (i), (ii) or (iii) above is to be
settled by delivery of shares of capital stock of our company or such other securities, in cash or otherwise.

Financial Statements

General

 6. Please ensure that your financial statements and corresponding financial information comply with the updating requirements
of Item 8 of the Form 20-F. Refer specifically to the instructions to Item 8.A.4. of Form 20-F.

We have filed with the First Amendment a request
for a waiver from the obligations of Item 8.A.4 of Form 20-F, as (i) we are not yet a public reporting company in any other jurisdiction
and are not required by any jurisdiction to prepare financial statements, (ii) compliance with Item 8.A.4 is impractical and involves
undue hardship for our company, (iii) our audited financial statements will not be available until April 1, 2015 and (iv) we will
not seek effectiveness of our registration statement if our audited financial statements are older than 15 months at the time of
the offering. Such request has been filed as Exhibit 99.1 to the First Amendment.

 7. You have determined that the 15 million common shares issued to Mr. Zuoqiao Sun Zhang represented nominal issuances pursuant
to SAB Topic 4:D. In this regard, you revised your financial statements, which resulted in your now reporting basic earnings per
share amounts of $0.28 for 2014 and $0.25 for 2013 compared to previously reported amounts of $3.41 for 2014 and $3.05 for 2013.
Please help us understand how you determined that these revisions should not be reflected as a correction of an error pursuant
to ASC 250.

We acknowledge the comment and respectfully
advise the Staff that we do not believe these revisions shall be reflected as a correction of error pursuant to ASC 250-10-20,
because these nominal stock issuances and repurchases did not exist at the time the financial statements were prepared. The Company’s
nominal issuances of shares to Mr. Zuoqiao Sun Zhang and related stock split, together with the related stock repurchase, were
fully completed on April 29, 2015 for the purpose of recapitalization before IPO. They were subsequent to our issuance of consolidation
financial statements for the years ended December 31, 2014 and 2013 on April 10, 2015. In accordance with SAB Topic 4:C, “A
capital structure change to a stock dividend, stock split or reverse split occurs after the date of the latest reported balance
sheet but before the release of the financial statements or the effective date of the registration statement, whichever is later.
Such changes in the capital structure must be given retroactive effect in the balance sheet. An appropriately cross-referenced
note should disclose the retroactive treatment, explain the change made and state the date the change became effective”.
Therefore the Company updated the registration statement and presented “Retroactively restated” on the face of the
consolidated financial statement for this impact.

 8. Please advise how you determined that it was appropriate to reflect the repurchase of four million shares on April 29, 2015
on a retroactive basis similar to stock split or dividend pursuant to ASC 260.

We acknowledge the comment and respectfully
advise the Staff that all the existing shareholders and directors of the Company consider the repurchase of four million shares
on April 29, 2015 was part of the company’s recapitalization to result in 12,000,000 common shares issued and outstanding
prior to completion of this offering. This recapitalization of repurchase of four million shares was due to negotiations with our
placement agent regarding the pre-IPO value of our company. Due to the lower enterprise value and minimum per-share IPO price,
our best solution to the valuation issue was to reduce the number of outstanding shares. No cash or other consideration was paid
for this repurchase. The Company believes the repurchase, in substance, is a correction to the nominal issuance of 15 million shares
to Mr. Zuoqiao Sun Zhang, therefore, it was appropriate to reflect the repurchase of four million shares on April 29, 2015 on a
retroactive basis similar to stock split or dividend pursuant to ASC 260.

Pamela A. Long, Assistant Director

February 4, 2016

Page 4

Note 1 – Business Description

Reorganization, page F-8

 9. We note your response to comment 12 of our letter dated July 13, 2015. It is unclear when the reorganization amongst Xibolun
Equipment, Xibolun Automation, HK Xibolun, and Hebron Technology took place and who specifically held what percentage of voting
ownership interests in each of these entities immediately prior to the reorganization. Please provide us the names of the specific
owners and corresponding voting ownership percentages for each of these entities immediately prior to the reorganization. Please
tell us how you determined that all of these entities were under common control by explaining the relationships between the different
owners, if applicable.

We acknowledge the comment and respectfully provide the Staff
with the following charts to illustrate the related questions:

Xibolun Equipment

Reorganization: Anyuan Sun transferred shares to Xibolun Automation
on July 29, 2013

    Shareholder

    Original Ownership

    Post-Reorganization Ownership

    Relationship with Mr. Anyuan Sun

    HK Xibolun

    30%

    30%

    At July 29, 2013, HK Xibolun was a wholly owned subsidiary of Hebron Technology, which is controlled by Mr. Anyuan Sun.

    Anyuan Sun

    70%

    0%

    Self.

    Xibolun Automation

    0%

    70%

    At July 29, 2013, Xibolun Automation was wholly owned by HK Xibolun, which is controlled by Mr. Anyuan Sun.

Xibolun Automation

Reorganization: Hebron Technology, Xibolun Equipment and Zhejiang
Xibolun Technology transferred shares to HK Xibolun on December 5, 2012

    Shareholder

    Original Ownership

    Post-Reorganization Ownership

    Relationship with Mr. Anyuan Sun

    Hebron Technology

    80%

    0%

    At December 5, 2012, Hebron Technology was held by Mr. Zuoqiao Sun Zhang, who nominally held the shares for his son, Mr. Anyuan Sun.

    Xibolun Equipment

    10%

    0%

    At December 5, 2012, 70% of the equity of Xibolun Equipment was held by Mr. Anyuan Sun. 30% of the equity of Xibolun Equipment was held by HK Xibolun, which was controlled by Mr. Anyuan Sun.

        Zhejiang Xibolun

        Technology

    10%

    0%

    At December 5, 2012, 70% of the equity of Zhejiang Xibolun Technology was held by Mr. Anyuan Sun.

    HK Xibolun

    0%

    100%

    At December 5, 2012, HK Xibolun was a wholly owned subsidiary of Hebron Technology, which is controlled by Mr. Anyuan Sun.

Pamela A. Long, Assistant Director

February 4, 2016

Page 5

HK Xibolun

Reorganization: Shih Chang Chen transferred shares to Hebron
Technology on October 22, 2012

    Shareholder

    Original Ownership

    Post-Reorganization Ownership

    Relationship with Mr. Anyuan Sun

    Anyuan Sun*

    100%

    0%

    Self

    Hebron Technology

    0%

    100%

    At October 22, 2012, Hebron Technology was held by Mr. Zuoqiao Sun Zhang, who nominally held the shares for his son, Mr. Anyuan Sun.

Hebron Technology

Reorganization:

    Shareholder

    Original Ownership

    Post-Reorganization Ownership

    Relationship with Mr. Anyuan Sun

    Anyuan Sun**

    100%

    100%

    Self.

*	      The equity was
held by Mr. Shih Chang Chen, a friend of Mr. Anyuan Sun. He nominally held the shares on behalf of Mr. Anyuan Sun’s brother,
Mr. Lingmin Sun, who nominally held the shares for Mr. Anyuan Sun.

**     The equity was
held by Mr. Zuoqiao Sun Zhang, father of Mr. Anyuan Sun. He is nominally holding the shares in Hebron Technology for Mr. Anyuan
Sun since August 5, 2013.

In preparation of IPO, the Company started
to reorganize the legal structure of the Company and its subsidiaries in Octob