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NIU
TECHNOLOGIES

No.1 Building, No. 195 Huilongguan East Road,

Changping District, Beijing 102208

People’s Republic of China

July 21, 2023

VIA EDGAR

Ms. Jennifer Thompson

Mr. Chris Dunham

Division of Corporation Finance

Office of Manufacturing

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:
    Niu Technologies (the “Company”)

    Annual Report on Form 20-F
    for the Fiscal Year Ended December 31, 2022

    Filed on April 21, 2023

    File No. 001- 38696

Dear Ms. Thompson
and Mr. Dunham:

Following the conference call with the staff (the
 “Staff”) of the Securities and Exchange Commission (the “Commission”) on July 19, 2023, this
letter sets forth the Company’s supplemental response to the Staff’s follow-up comment with respect to comment No. 6
contained in the Staff’s letter dated June 26, 2023 regarding 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 “2022 Form 20-F”). The
Staff’s comment is repeated below in bold and followed by the Company’s response thereto. All capitalized terms used but not
defined in this letter shall have the meaning ascribed to such terms in the 2022 Form 20-F.

Form 20-F for the Fiscal Year Ended
December 31, 2022

Item 16I. Disclosure Regarding Foreign Jurisdictions
that Prevent Inspections, page 137

 6. 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.

Division of Corporation Finance

Office of Manufacturing

Securities
and Exchange Commission

July 21, 2023

Page 2

The Company respectfully submits to
the Staff that, as part of the Company’s annual compliance and reporting procedures for the Form 20-F filing, the Company has
required all of its directors to complete a questionnaire, which seeks confirmation regarding their status as official of the Chinese
Communist Party. Each director has confirmed that he or she is not an official of the Chinese Communist Party or affiliated with committees
of the Chinese Communist Party in their respective questionnaires. By signing such questionnaire, each director has certified the accuracy
of his or her responses to the questionnaire. Based on these certifications provided by its directors, the Company believes that none
of the members of the board of directors of Niu Technologies is an official or affiliate of the Chinese Communist Party.

The Company further respectfully submits
that the VIE and the Company’s other consolidated operating entities do not have their own board of directors. Instead, they are
managed by a sole director or an executive director who is also an employee of the Company. As part of their employment onboarding process,
these directors are required to provide their background information, including any party affiliation, to the Company. They have all confirmed
that they are not members of the Chinese Communist Party. The Company has emphasized that providing accurate background information is
a condition of their employment, and they have represented to the Company in their employment agreements that the information they provided
to the Company is true and accurate. In addition, if any of these directors intend to join the Chinese Communist Party, they need to obtain
a certificate from the Company to verify their employment status as part of the normal application process. To date, the Company has not
received from these directors any such request for certificates in connection with their applications to join the Chinese Communist Party.
Based on the information provided by the directors the VIE and the Company’s other consolidated operating entities, the Company
believes that none of them is a member of the Chinese Communist Party.

As
illustrated above, each of the Company’s directors and directors of the VIE and other consolidated operating entities is obligated
to confirm their status whether he or she is a member or an official of the Chinese Communist Party to the Company. The Company believes
it is reasonable and sufficient to rely on such information provided by the relevant personnel as the basis of its submission that
none of them is an official of the Chinese Communist Party.

*          *          *

If you have any additional
questions or comments regarding the 2022 Form 20-F, please contact the undersigned at +86 10-6432-1899 or the Company’s U.S.
counsel, Shu Du of Skadden, Arps, Slate, Meagher & Flom LLP at +852 3740 4858 or shu.du@skadden.com.

    Sincerely yours,

    Niu Technologies

    By:
    /s/ Fion Wenjuan Zhou

    Name: Fion Wenjuan Zhou

    Title: Chief Financial Officer

    cc:
    Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP