SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631

       DIVISION OF
CORPORATION FINANCE

  Mail Stop 4631

June 1, 2017

Via E-Mail
Mr. Huang Jiancong
Chief Executive Officer
ZK International Group Co., Ltd.
c/o Zhejiang  Zhengkang Industrial Co., Ltd.
No. 678 Dingxiang Road, Binhai Industrial Park
Economic & Technology Development Zone
Wenzhou, Zhejiang Province
People’s Republic of China 325025

Re: ZK International Group Co., Ltd.
Registration Statement  on Form F -1
Submitted May 2 4, 2017
  File No. 333 -218198

Dear Mr. Huang :

We have limited our review of your registration statement to those issues that we
have addressed in our comments.  In our comments  we may ask you to provide us
information so that we may better understand your disclosure.

Prospectus’ Outside Front  Cover Page; Underwriting, page 85

1. Disclosure on the prospectus’ outside front cover page that all funds will be returned
promptly to investors within three business days if you do not sell at least 1,000,000
ordinary shares by September 30, 2017 is incon sistent with disclosure in the
underwriting section that all funds will be returned promptly to investors within five
business days if you do not sell at least 1,000,000 ordinary shares by September 30,
2017.  Please reconcile the disclosures.

We are subs tantially dependent upon our senior management…, page 17; Management,
page 63

2. Disclosure that Mr. Jiancong Huang is your interim chief financial officer is
inconsistent with disclosure in the management section and elsewhere that Ms.
Shaochai Yang is your  chief financial officer.  Pleas e reconcile the disclosures.

Mr. Huang J iancong
ZK International Group Co., Ltd.
June 1 , 2017
Page 2

 We plan to have a classified board structure…, page 27; Board of Directors, page 64;
Director Compensation, page 67

3. Your risk factor discloses that you will have a classified board structure, b ut your
revised disclosure in the board of directors section does not confirm this.  Please
clarify whether you plan to have a classified board structure, and in your disclosures
regarding the board of directors, ensure that you state the date of expiration of the
current term for each director.

Board Committees, page 65

4. Identify the members of each board committee, and indicate the chair of each board
committee.

Compensation Committee, page 66; Governance Committee, page 66

5. Disclosure indicates that the compensation committee is to review and make
recommendations about all forms of compensation to be provided to your directors
and executive officers.  Disclosure indicates also that the governance committee is to
review matters of compen sation and recommend awards under your long term and
short term incentive plans.  Elaborate on how the compensation committee and the
governance committee will coordinate what appear to be joint compensation
responsibilities.

Underwriting, page 85

6. We not e your response to comment 9 in our April 20 , 2017  letter.  Please revise your
discussion of the escrow agreement to  identify  correctly the escrow agent.  Your
current discl osure references Signature Bank.

Financial Statements

General

7. We remind you that  if your filing does not become effective by June 30, 2017, you
will need to update your financial statements to include unaudited financial
statements for the six months ended June 30, 2017.   Refer to Rule 3 -12 of
Regulations S -X and Item 8.A.5 of Form 20 -F.

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.

Mr. Huang J iancong
ZK International Group Co., Ltd.
June 1 , 2017
Page 3

Refer to Rules 460 and 461 regarding requests for a cceleration.  Please allow
adequate time for us to review any amendment before the requested effective date of the
registration statement.

You may contact SiSi Cheng , Staff Accountant, at (202) 551 -5004  or Kevin W.
Stertzel , Staff Accountant , at (202) 551-3723  if you have questions about comments on
the financial statements and related matters.  You may contact Edward M. Kelly, Special
Counsel, at (202) 551 -3728 or me at (202) 551 -3765 if you have any other questions .

Very truly yours ,

      /s/ Pamela A. Long

      Pamela A. Long
      Assistant Director
      Office of Manufacturing and Construction

cc: Via E -mail
William S. Rosenstadt, Esq.
Mengyi “Jason” Ye, Esq.
Ortoli Rosenstadt LLP
501 Madison Avenue, 14th Floor
New York, NY 10022