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July 21, 2023
Gloria Fan
Chief Financial Officer
BEST Inc.
2nd Floor, Block A, Huaxing Modern Industry Park
No. 18 Tangmiao Road, Xihu District, Hangzhou
Zhejiang Province 310013
People’s Republic of China
Re:BEST Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 21, 2023
File No. 001-38198
Dear Gloria Fan:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comments.  In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 146
1.We note your statements that none of your directors or officers are representatives of any
PRC government entity and that no shareholder who beneficially owns 10% or more of
your total outstanding ordinary shares is controlled by any PRC government entity in
connection with your required submission under paragraph (a).  Please supplementally
describe any materials that were reviewed and tell us whether you relied upon any legal
opinions or third party certifications such as affidavits as the basis for your submission.  In
your response, please provide a similarly detailed discussion of the materials reviewed and
legal opinions or third party certifications relied upon in connection with the required
disclosures under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you

 FirstName LastNameGloria Fan
 Comapany NameBEST Inc.
 July 21, 2023 Page 2
 FirstName LastName
Gloria Fan
BEST Inc.
July 21, 2023
Page 2
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party.  For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.  In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note your statement under Item 16I(b) that your consolidated foreign operating
entities are incorporated or otherwise organized in the PRC.  We also note your list of
significant subsidiaries and consolidated variable interest entity in Exhibit 8.1, which
appears to indicate that you have subsidiaries outside the PRC.  Please note that Item
16I(b) requires that you provide disclosures for yourself and your consolidated foreign
operating entities, including variable interest entities or similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and provide the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities in your supplemental response.
•With respect to (b)(3), (b)(4) and (b)(5), please provide the required information for
you and all of your consolidated foreign operating entities in your supplemental
response.
            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.
            Please contact Tyler Howes at 202-551-3370 or Jennifer Thompson at 202-551-3737
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Yi Gao, Esq.