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ZK INTERNATIONAL GROUP CO., LTD.

No. 678 Dingxiang Road, Binhai Industrial Park

Economic & Technology Development Zone

Wenzhou, Zhejiang Province

People’s Republic of China 325025

June 30, 2022

Via Electronic Mail

Dale Welcome

Division of Corporation Finance

Office of Manufacturing

U.S. Securities Exchange Commission

    Re:
    ZK International Group Co., Ltd. (the “Company”)

To whom it may concern:

This letter is in response to the letter dated
May 26, 2022 from the staff (the “Staff”) of the U.S. Securities Exchange Commission (“SEC”) addressed to ZK International
Group Co., Ltd. (the “Company”, “we”, and “our”). For ease of reference, we have recited SEC’s
comments in this response and numbered them accordingly. An amended 20-F (the “Form 20-F/A”) is being submitted to accompany
this letter.

Form 20-F for the Fiscal Year Ended September
30, 2021

Part I, page 5

 1. At the onset of Part I, please revise to disclose prominently the following:

 • whether your auditor is subject to the determinations announced by the PCAOB on December 16, 2021;

 • whether and how the Holding Foreign Companies Accountable Act, the Accelerating
Holding Foreign Companies Accountable Act, and related regulations will affect your company, including the time frame change in PCAOB
inspections to two consecutive years instead of three years;

 • whether you have been or are expect to be identified by the Commission under
the HFCAA; and

 • a cross-reference to more detailed disclosures in your risk factors, including
the heading of the risk factor.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we added the required disclosure in a section titled “Implications of
the Holding Foreign Companies Accountable Act (“HFCAA”)” on page 6 of the Form 20-F/A that ZH CPA, LLC is not subject
to the determinations as to the inability to inspect or investigate registered firms completely announced by the PCAOB on December 16,
2021. In the event it is later determined that the PCAOB is unable to inspect or investigate completely the Company’s auditor because
of a position taken by an authority in a foreign jurisdiction, then such lack of inspection could cause trading in the Company’s
securities to be prohibited under the HFCAA ultimately result in a determination by a securities exchange to delist the Company’s
securities. In addition, under the HFCAA, our securities may be prohibited from trading on the Nasdaq or other U.S. stock exchanges if
our auditor is not inspected by the PCAOB for three consecutive years, which could be reduced to two consecutive years if the Accelerating
Holding Foreign Companies Accountable Act is signed into law, and this ultimately could result in our ordinary shares being delisted by
and exchange, Neither ZK International nor any of its subsidiaries has been identified and we do not expect ZK International or any of
its subsidiaries to be identified by the Commission under the HFCAA.. We have also added cross-reference to the risk factor “Item
3.D Risk Factors – Risk Related to our Ordinary Shares – Our ordinary shares may be delisted under the Holding Foreign Companies
Accountable Act if the PCAOB is unable to inspect our auditors for three consecutive years beginning in 2021. The delisting of our ordinary
shares, or the threat of their being delisted, may materially and adversely affect the value of your investment.”

In addition, we revised “Item 3. Key Information
 – Summary of Risk Factors – Risk Related to our Ordinary Shares – Risks that trading in our securities may be prohibited
under the Holding Foreign Companies Accountable Act if the PCAOB determines that it cannot inspect or investigate completely our auditor
and that as a result an exchange may determine to delist our securities” on page 15 of the Form 20-F/A and “Item 3.D Risk
Factors – Risk Related to our Ordinary Shares – Our ordinary shares may be delisted under the Holding Foreign Companies Accountable
Act if the PCAOB is unable to inspect our auditors for three consecutive years beginning in 2021. The delisting of our ordinary shares,
or the threat of their being delisted, may materially and adversely affect the value of your investment” starting on page 41 of
the Form 20-F/A to dislose the required information.

 2. At the onset of Part I, please disclose prominently that you are not a Chinese operating company but
a British Virgin Islands holding company with operations conducted by your subsidiaries, primarily based in China, and that this structure
involves unique risks to investors. Provide a cross-reference to your detailed discussion of risks facing the company as a result of this
structure.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we added the required disclosure in the first paragraph of the section titled
 “Corporate Structure and the Risks Relating to Being a China-based Company” on page 7 of the Form 20-F/A and added a cross-reference
to the risk factors “Item 3.D Risk Factors — Risks Related to Our Corporate Structure —ZK International is a holding
company and will rely on dividends paid by our subsidiaries for our cash needs. Any limitation on the ability of our subsidiaries to make
dividend payments to us, or any tax implications of making dividend payments to us, could limit our ability to pay our expenses or pay
dividends to holders of our ordinary shares.” on page 40 and “PRC regulation of loans to and direct investment in PRC entities
by offshore holding companies to PRC entities may delay or prevent us from making loans or additional capital contributions to our PRC
operating subsidiaries.”

 3. At the onset of Part I, please provide prominent disclosure about the legal and operational risks associated
with being based in or having the majority of the company’s operations in China. Your disclosure should make clear whether these
risks could result in a material change in your operations and/or the value of your ordinary shares or could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline
or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s government, such as those
related data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business, accept foreign
investments, or list on a U.S. or other foreign exchange.

RESPONSE: We note the Staff’s
comment, and in response hereto, respectfully advise the Staff that we added the required disclosure in the second paragraph of the
section titled “Corporate Structure and the Risks Relating to Being a China-based Company” on page 7
of the Form 20-F/A.

 4. We note your disclosures on page 3; however, when you provide disclosure throughout the filing please
make it clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting business operations.
Refrain from using terms such as “we” or “our” when describing activities or functions of a subsidiary. For example,
disclose, if true, that your subsidiaries conduct operations in China and that the holding company does not conduct operations. Disclose
clearly the entity (including the domicile) in which investors own an interest.

RESPONSE: We note the Staff’s
comment, and in response hereto, respectfully advise the Staff that we have revised our disclosure throughout the Form 20-F/A, to
make it clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business
operations and, to refrain from using terms such as “we” or “our” when
describing activities or functions of a subsidiary or other entity, and that our subsidiaries conduct operations in China and that
the holding company does not conduct operations. We also added a statement on page 3 of the Form 20-F/A that Investors are cautioned
that you own interest in ZK International, the holding company established in the British Virgin Islands that does not have conduct
material operations. ZK International conducts business thought it subsidiaries, primarily based in China.

Item 3. Key Information, page 5

 5. At the onset of Item 3, please disclose the risks that your corporate structure and being based in
or having the majority of the company’s operations in China poses to investors. In particular, describe the significant regulatory,
liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the filing. For example, specifically
discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules
and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence
your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers,
which could result in a material change in your operations and/or the value of your ordinary shares. Acknowledge any risks that any actions
by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in
China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities to investors
and cause the value of such securities to significantly decline or be worthless.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we added a section titled “Summary of Risk Factors”, which included
subsections titled “Risks Related to Doing Business in China” and “Risks Related to Our Corporate Structures”
starting on page 7 of the Form 20-F/A.

 6. Please disclose each permission or approval that you or your subsidiaries are required to obtain from
Chinese authorities to operate your business and to offer securities to foreign investors. State whether you or your subsidiaries are
covered by permission requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or
any other governmental agency that is required to approve operations, and state affirmatively whether you have received all requisite
permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your
investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that
such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required
to obtain such permissions or approvals in the future.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we added the required disclosure under the section titled “PRC Permissions
and Approvals” on page 16 of the Form 20-F/A.

 7. At the onset of Item 3, please provide a clear description of how cash is transferred through your
organization. Disclose your intentions to distribute earnings or settle amounts owed under applicable agreements. Quantify any cash flows
and transfers of other assets by type that have occurred between the holding company and its subsidiaries and direction of transfer. Quantify
any dividends or distributions that a subsidiary have made to the holding company and which entity made such transfer, and their tax consequences.
Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make
clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your ability
to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to
distribute earnings from the company, including your subsidiaries to the parent company and U.S. investors as well as the ability to settle
amounts owed under applicable agreements.

RESPONSE: We note
the Staff’s comment, and in response hereto, respectfully advise the Staff that we added the required disclosure under the section
titled “Cash and Asset Transfers within the Corporate Structure” starting on page 16 of the Form 20-F/A.

 8. Please disclose that trading in your securities may be prohibited under the Holding Foreign Companies
Accountable Act if the PCAOB determines that it cannot inspect or investigate completely your auditor, and that as a result an exchange
may determine to delist your securities. Disclose whether your auditor is subject to the determinations announced by the PCAOB on December
16, 2021.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we added a section titled “Implications of the Holding Foreign Companies
Accountable Act (“HFCAA”)” on page 6 of the Form 20-F/A. We also highlighted such risk in ““Item 3. Key
Information – Summary of Risk Factors – Risk Related to our Ordinary Shares – Risks that trading in our securities may
be prohibited under the Holding Foreign Companies Accountable Act if the PCAOB determines that it cannot inspect or investigate completely
our auditor and that as a result an exchange may determine to delist our securities” on page 15 of the Form 20-F/A,

A. Selected Financial Data, page 5

 9. Please ensure amounts presented here correspond with amounts presented in your financial statements.
In this regard, we note you disclose income from operations for the year ended September 30, 2021; however, you disclose an operating
loss in your financial statements.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we revised the section titled “Selected Financial Data” on page
18 of the Form 20-F/A to reconcile the amount with the audited financial statements.

D. Risk Factors, page 6

 10. Given the Chinese government’s significant oversight and discretion over the conduct of your
business, please revise to highlight separately the risk that the Chinese government may intervene or influence your operations at any
time, which could result in a material change in your operations and/or the value of your securities. Also, given recent statements by
the Chinese government indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China- based issuers, acknowledge the risk that any such action could significantly limit or completely hinder your ability
to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

RESPONSE: We note the Staff’s
comment, and in response hereto, respectfully advise the Staff that we added a risk factor titled
 “The Chinese government may intervene or influence the operations of the PRC subsidiaries
at any time. Such risks may result in a material change in the operations of the PRC subsidiaries, significant depreciation of the
value of our ordinary shares, or a complete hindrance of our ability to offer or continue to offer our securities to investors and
cause the value of such securities to significantly decline or be worthless” on page 32 of the Form 20-F/A.

 11. Since your officers and directors are located in China, as disclosed in your risk factor on page 21,
please revise to also include a separate Enforceability section to disclose the difficulty of bringing actions and enforcing judgements
against these individuals.

RESPONSE: We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we revised the risk factor “Since the operations of the PRC subsidiaries
and substantially all of our assets are located in the P