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ZTO Express (Cayman) Inc.

Building One, No. 1685 Huazhi Road

Qingpu District, Shanghai 201708

People’s Republic of China

November 13, 2023

VIA EDGAR

Mr. Gus Rodriguez

Mr. Robert Babula

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: ZTO Express (Cayman) Inc. (the “Company”)

    Form 20-F for the Fiscal Year
Ended December 31, 2022

    Filed April 20, 2023

    Response letter dated September 27,
2023

    File No. 001-37922

Dear Mr. Rodriguez
and Mr. Babula,

This
letter sets forth the Company’s responses to the comments contained in the letter dated October 16, 2023 from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s
annual report on Form 20-F for the fiscal year ended December 31, 2022 filed with the Commission on April 20, 2023 (the
“2022 Form 20-F”) and the Company’s response letter submitted on September 27, 2023. The Staff’s
comments are repeated below in bold and are followed by the Company’s responses thereto. All capitalized terms used but not defined
in this letter shall have the meaning ascribed to such terms in the 2022 Form 20-F.

Form 20-F for the Fiscal Year ended December 31, 2022

Condensed Consolidating Financial Information of ZTO Express
(Cayman) Inc., page 13

 1. We note your response to prior comment one explaining that your subsidiaries leased land, buildings, equipment and trucks to the
VIE’s and their subsidiaries, which recorded the rental fees in all cases as cost of revenues, while your subsidiaries recorded
the corresponding rental income as either revenues or other operating income “...based on the subsidiaries’ primary business
operations.” Please address the following points:

 ● Describe the accounting policies that you applied in determining whether rental income would be reported as revenue or as other
operating income, including how the nature of the VIE’s and their subsidiaries primary business operations were evaluated and considered
in accounting for the transactions.

    The Company respectfully
advises the Staff that in determining whether rental income would be reported as revenue or as other operating income, the Company considered
the primary business of the subsidiary. If the subsidiary’s primary business is to rent properties and earn rental income, the subsidiary
records rental income under revenue on its standalone financial statements. If the subsidiary’s primary business is to provide services
other than rental, such as, technical services or transportation services, the subsidiary records rental income from renting certain assets
under other operating income on its standalone financial statements.

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

November 13, 2023

Page 2

 ● Tell us how the leased land, buildings, equipment and trucks are used to generate revenues by your VIE’s.

The Company respectfully
advises the Staff that the properties leased by the VIE are used in the operation of its primary business, which is generating express
delivery services revenues. The leased land, buildings and equipment are used as the VIE’s sorting facilities and the leased trucks
are used in the VIE’s line-haul transportation operations. Accordingly, the rental costs associated with such leased properties
are recorded under the cost of revenues on the VIE’s standalone financial statements.

 ● Indicate the extent to which the leased property is attributable to selling, general and administrative purposes, and separately
to the generate of revenues, and explain to us the basis for your determinations in this regard.

The Company respectfully
advises the Staff that the rental cost incurred for the leased property that is attributable to selling, general and administrative purposes,
such as administrative office use, is recorded under selling, general and administrative expenses. In 2020, 2021 and 2022, RMB17 million,
RMB71 million and RMB91 million of rental costs for intercompany leases of office facilities were recorded under selling, general and
administrative expenses on the VIE’s standalone financial statements, respectively. The rental income related to the leased office
facilities have consistently been booked by the subsidiaries as other operating income and grouped into other operating income upon consolidation
of the Company’s financial statements. Therefore, the VIE’s selling, general and administrative expenses incurred for intercompany
leases have been eliminated against other operating income upon consolidation.

Given your statement that all intercompany transactions
were fully eliminated with no impact on revenue, cost of revenue, or gross profit, we understand that the elimination for cost of revenues
in excess of the elimination for revenues equates to the revenues that were booked by your subsidiaries as other operating income.

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

November 13, 2023

Page 3

Please confirm if this is the case or provide any additional
details necessary to understand the disparity with the eliminations in 2022.

The
Company respectfully advises the Staff that the elimination for cost of revenues in excess of the elimination for revenues plus
the rental cost recorded under selling, general and administrative expenses equal to the rental income that was included in the subsidiaries’
other operating income in Condensed Consolidating Financial Information on Page 18 of 2022 Form 20-F.

The following table sets forth the rental related eliminations
to further explain the disparity with the eliminations in 2022.

    RMB

(In thousands)
    Elimination due to

 intercompany

 services other than

 lease services
    Elimination due to

 intercompany lease

 services
    Total

eliminations

    Revenue
      (13,762,158 )
      -
      (13,762,158 )

    Cost of revenue
      13,762,158
      733,687
      14,495,845

    Selling, general and administrative
      -
      91,239
      91,239

    Other operating income, net
      -
      (824,926 )
      (824,926 )

 2. We understand from your response to prior comment one that all internal rental income from the lease arrangements for 2020 and
2021 is reported as revenue in the schedules on page 18 and therefore the eliminations for revenues and cost of revenues are equal
for these earlier periods. Tell us the amounts that were initially reported as other operating income for 2020 and 2021 and explain how
you formulated your view on materiality.

The
Company respectfully advises the Staff that in 2020 and 2021, the amounts that were initially reported as other operating income
of subsidiaries and grouped into revenue of subsidiaries upon consolidation were RMB168 million and RMB302 million, respectively.

The
Company believes the above-mentioned grouping upon consolidation is not quantitively or qualitatively material to the Company. The
amounts for the above-mentioned intercompany rental income represented approximately 1% and 2% of the subsidiaries’ total revenue
(before elimination) in 2020 and 2021, respectively. Substantially all of the subsidiaries’ revenue was generated from intercompany
transactions and eliminated upon consolidation. Furthermore, as disclosed in note 2(b) to the consolidated financial statements on
page F-17 of the 2022 Form 20-F, after elimination, the VIE contributed 94.1% and 97.7% of the Company’s consolidated
revenues for the years ended December 31, 2020 and 2021, respectively.

*               *               *

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

November 13, 2023

Page 4

If you have any additional questions or comments
regarding the 2022 Form 20-F, please contact the undersigned at +86 21 5980 4508 or the Company’s U.S. counsel, Haiping Li
of Skadden, Arps, Slate, Meagher & Flom LLP at +86 21 6193 8210 or haiping.li@skadden.com, or Yuting Wu of Skadden, Arps, Slate,
Meagher & Flom LLP at +86 21 6193 8225 or yuting.wu@skadden.com. Thank you very much.

   Very truly yours,

    /s/
Huiping Yan

    Huiping Yan

    Chief Financial Officer

cc: Meisong Lai, Chairman of the Board
of Directors and Chief Executive Officer, ZTO Express (Cayman)
Inc.

  Haiping Li, Esq., Partner, Skadden, Arps,
Slate, Meagher & Flom LLP

  Yuting Wu, Esq., Partner, Skadden, Arps,
Slate, Meagher & Flom LLP

  Anna Li, Partner, Deloitte Touche Tohmatsu Certified
Public Accountants LLP

[Signature Page to 20-F Response Letter]