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Simpson
Thacher & Bartlett

ICBC TOWER, 35TH FLOOR

3 GARDEN ROAD, CENTRAL

HONG KONG

TELEPHONE:
+852-2514-7600

FACSIMILE:
+852-2869-7694

    Direct Dial Number

 +852-2514-7620
    E-mail
Address

ygao@stblaw.com

July 31, 2023

CONFIDENTIAL
AND VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Ms. Jennifer Thompson

    Mr. Tyler Howes

Re:
     BEST Inc.
 Form 20-F for the Fiscal Year Ended December 31, 2022
 Filed
April 21, 2023
 File No. 001-38198

Ladies and Gentlemen:

On behalf of our
client, BEST Inc., a company organized under the laws of the Cayman Islands (the “Company”), we respond to the comments
contained in the letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
dated July 21, 2023 (the “July 21 Comment Letter”) relating to the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2022 filed with the Commission on April 21, 2023 (the “Annual Report”).

Set forth below
are the Company’s responses to the Staff’s comments in the July 21 Comment Letter. The Staff’s comments are retyped
below in bold italic font for your ease of reference. The Company respectfully advises the Staff that where the Company proposes to add
or revise disclosure in its future annual reports on Form 20-F in response to the Staff’s comments, the changes to be made
will be subject to relevant factual updates and changes in relevant laws or regulations, or in interpretations thereof.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    ADAM
S. GOLDBERG
    MAKIKO HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    kathryn
    kING  sudol
    christopher
    k.s. wong

    resident
    partners

simpson thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson Thacher & Bartlett

    July 31, 2023
    -2-
    Division of Corporation Finance

U.S. Securities and Exchange Commission

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).

The Company respectfully advises
the Staff that the Company checked and confirmed with all of the Company’s directors and officers in order to confirm that none
of such directors or officers are representatives of any government entity in the PRC. Most of the Company’s directors have non-PRC
nationalities and therefore would not be eligible for membership in the Chinese Communist Party (“CCP”), let alone
being any representative of any government entity in the PRC.

As to the Company’s
shareholders that beneficially own 10% or more of the total outstanding ordinary shares of the Company, namely, (i) Mr. Shao-Ning
Johnny Chou, the Company’s founder, chairman and chief executive officer, and (ii) Alibaba Group Holding Limited, Mr. Chou
has U.S. nationality, and to the best of our knowledge, neither Mr. Chou nor Alibaba Group Holding Limited is controlled by any
government entity in the PRC.

The Company did not rely upon
any legal opinions or third party certifications such as affidavits in connection with its required submission under Item 16I(a).

In connection with the required
disclosures under Item 16I(b)(2) and (3), as to the Company itself, the Company respectfully advises the Staff that the Company
checked and confirmed its register of members in order to confirm that, to the best of its knowledge, (b)(2) no governmental entity
in the PRC or the Cayman Islands owns any shares of the Company, and (b)(3) no governmental entity in the PRC has a controlling
financial interest with respect to the Company.

In connection with the required
disclosures under Item 16I(b)(2) and (3), as to the consolidated foreign operating entities, and as such disclosures have been revised
and updated pursuant to Comment 3 of the July 21 Comment Letter, the Company checked and confirmed the shareholdings of the consolidated
foreign operating entities, most of which are held as to 100%, in order to confirm that, to the best of its knowledge, (b)(2) no
governmental entity in any of the PRC, the British Virgin Islands, Hong Kong, the Cayman Islands, Thailand, Vietnam, Malaysia, Singapore
or Cambodia owns any shares of any of the consolidated foreign operating entities, and (b)(3) no governmental entity in the PRC
has a controlling financial interest with respect to any of the consolidated foreign operating entities.

    Simpson Thacher & Bartlett

    July 31, 2023
    -3-
    Division of Corporation Finance

U.S. Securities and Exchange Commission

The Company did not rely upon
any legal opinions or third party certifications such as affidavits in connection with its required disclosures under Item 16I(b)(2) and
(3).

2. In
                                            order to clarify the scope of your review, please supplementally describe the steps you 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.

The Company respectfully advises
the Staff that the Company checked and confirmed with all of its directors, and all of the directors of its consolidated foreign operating
entities, in order to confirm that none of such members are officials of the CCP. Most of the Company’s consolidated foreign operating
entities have one sole director; in most cases, this sole director is Mr. Shao-Ning Johnny Chou. In the minority of cases where
a consolidated foreign operating entity of the Company has multiple directors on its board, including Mr. Chou and other directors,
most of the other directors have non-PRC nationalities and therefore would not be eligible for membership in, let alone being any official
of, the CCP. The Company did not rely upon third party certifications such as affidavits in connection with its 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.

    Simpson Thacher & Bartlett

    July 31, 2023
    -4-
    Division of Corporation Finance

U.S. Securities and Exchange Commission

In response to the Staff’s
comment, in the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2023, the Company will revise
its disclosures under Item 16I(b), consistent with the updated disclosures set forth in Annex A.

*	     *	     *

    Simpson Thacher & Bartlett

    July 31, 2023
    -5-
    Division of Corporation Finance

U.S. Securities and Exchange Commission

If you have any
question regarding the Company’s responses to the Staff’s comments, please do not hesitate to contact me at +852-2514-7620
(work), +852-6588-7136 (mobile) or ygao@stblaw.com (email).

    Very truly yours,

    /s/ Yi Gao

    Yi Gao

Enclosure:	     Annex
A

cc: Shao-Ning
                                            Johnny Chou, Chief Executive Officer

George Chow, Chief Strategy
and Investment Officer

Gloria Fan, Chief Financial
Officer

BEST Inc.

Annex A

Comment 3

Our company is incorporated in the Cayman
Islands. The VIEs and other operating entities being consolidated in our financial statements, or the consolidated foreign operating
entities, are incorporated or otherwise organized in the PRC, the British Virgin Islands, Hong Kong, the Cayman Islands, Thailand, Vietnam,
Malaysia, Singapore or Cambodia.

To the best of our knowledge, no governmental
entity in any of the PRC, the British Virgin Islands, Hong Kong, the Cayman Islands, Thailand, Vietnam, Malaysia, Singapore or Cambodia
owns any shares of our company or any of the consolidated foreign operating entities.

To the best of our knowledge, no governmental
entity in the PRC (i.e. the applicable foreign jurisdiction with respect to Ernst & Young Hua Ming LLP) has a controlling financial
interest with respect to our company or any of the consolidated foreign operating entities.

No member of the board of directors
of our company or any of the consolidated foreign operating entities is any official of the Chinese Communist Party.

Neither the memorandum and articles
of association of our company nor the articles of incorporation (or equivalent organizing document) of any of the consolidated foreign
operating entities contains any charter of the Chinese Communist Party.