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CORRESP
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ZK International
Group Co., Ltd.

c/o Zhejiang Zhengkang Industrial

Co., Ltd.

No. 678 Dingxiang Road, Binhai Ind. Park

Economic & Technology Development
Zone

Wenzhou, Zhejiang Province

People’s Republic of China 325025

April 26, 2019

Via E-Mail

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4631

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

Registration Statement on Form F-3

File No. 333-230860 (the “Registration
Statement”)

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred
to above be accelerated so that it will be declared effective at 3:00 p.m., Eastern Time, on April 29, 2019, or as soon thereafter
as is practicable.

If there is any change in the acceleration
request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request
of acceleration of the effectiveness of the F-1 Registration Statements in accordance with Rule 461. The request may be made by
an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Ortoli Rosenstadt LLP.

The Company acknowledges that:

 · should the Commission or the staff, acting
pursuant to delegated authority, declares the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

 · the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

 · the Company may not assert staff comments
and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

If you have any further questions, please
contact William Rosenstadt, Esq. or Jason “Mengyi” Ye, Esq., at +1 (212) 588-0022, from the Company’s U.S. counsel,
Ortoli Rosenstadt LLP.

    Very
    truly yours,

    ZK International Group Co., Ltd.

    By:
    /s/ Jiancong Huang

    Name:
    Jiancong Huang

    Title:

        Chairman of the Board and

        Chief Executive Officer