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CORRESP
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Qilian International Holding Group Ltd.

November 27, 2019

VIA EDGAR

Ms. Bonnie Baynes

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Healthcare & Insurance

100 F Street, N.E.

Mail Stop 4631

Washington, DC 20549

    Re:

        Qilian International Holding Group Ltd.

        Amendment No. 1 to Registration Statement on Form F-1

        Submitted November 1, 2019

        File No. 377-02698

Dear Ms. Baynes:

Qilian International
Holding Group Ltd. (the “Company”, “Qilian,” “we”, “us”
or “our”) hereby transmits its response to the letter received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”), dated November 12, 2019 regarding its Registration
Statement on Form F-1 (the “Registration Statement”) publicly submitted on November 1, 2019. For ease of reference,
we have repeated the Commission’s comments in this response letter and numbered them accordingly. An Amendment No.1 to the
Registration Statement on Form F-1 (“Amendment No.1”) is being submitted publicly to accompany this response
letter.

Registration Statement on Form F-1

Prospectus Summary

Our History and Corporate Structure,
page 7

1. We note your response to comments
3 and 6. Please clarify whether Gansu QLS or any of its subsidiaries are restricted in the amount of capital they are able to contribute
to WFOE or the amount of capital they are able to repatriate from WFOE as a result of noncompliance with PRC SAFE Circular 37.

Response: The Company respectfully
advises the Staff that since Gansu QLS and its subsidiaries are only controlled by WFOE through contractual arrangements and since
WFOE is not a shareholder of Gansu QLS, neither Gansu QLS nor any of its subsidiaries have any obligations to contribute capital
to WFOE, nor have they any rights to receive distributions or dividends from WFOE. In addition, pursuant to the Notice of State
Administration of Foreign Exchange on Promulgation of the Provisions on Foreign Exchange Control on Direct Investments in China
by Foreign Investors promulgated by the State Administration of Foreign Exchange, upon establishment of a foreign investment enterprise
pursuant to the law, registration formalities shall be completed with the foreign exchange bureau. Upon completion of such registration
formalities, foreign investment enterprises are able to open bank accounts for direct investment in China, conduct settlement when
contributing foreign exchange funds, and remit funds overseas in the event of such as profit distribution. WFOE is not subject
to any restrictions on capital contribution or repatriation because WFOE has completed the foreign exchange registration formalities
as required upon its establishment. Finally, only capital contributions to a special purpose vehicle by its shareholders failing
to comply with Circular 37, as well as the repatriation of profits and dividends derived from such special purpose vehicle to China
by its shareholders are limited. The Company has updated its disclosure on pages 7 and 88 of Amendment No.1 accordingly.

Selected Financial Data, page 10

2. We note that your basic and diluted
earnings per ordinary share, weighted average shares, and shares issued and outstanding on pages 10 and 11 are not consistent with
that disclosed in your interim unaudited financial statements. Please revise to consistently disclose the effects of your reverse
stock split and ordinary share increase retroactively to the earliest period presented throughout your filing.

Response: In response to the Staff’s
comment, the Company revised its disclosure on pages 10 and 11 of the Amendment No.1.

Risk Factors

Risks Related to the Offering and
Our Ordinary Shares

Our choice of forum provisions in
our Articles of Associates may limit, page 21

3. We note your disclosure on pages
21 and 109 that your Articles of Association include an exclusive forum provision. However, your Form of Amended and Restated Memorandum
and Articles of Association filed as Exhibit 3.3 does not appear to have an exclusive forum provision. Please tell us whether the
Restated Memorandum and Articles of Association filed as Exhibit 3.3 will become effective prior to the close of the offering,
and, if so, please revise your disclosure so that it is consistent with Exhibit 3.3.

Response: The Company respectfully
informs the Staff that the Company’s Amended and Restated Memorandum and Articles of Association became effective on October
16, 2019 and does not include an exclusive forum provision. The Company updated its disclosures on pages 21 and 109 of Amendment
No.1 accordingly.

Business

Research and Development

R&D Achievements, page 77

4. We note your disclosure that the
cooperation agreement between Gansu QLS and the Wuxi Company has expired. However, we note that the agreement provided that the
applied intellectual properties developed pursuant the cooperation agreement are equally owned by the Gansu QLS and the Wuxi Company
and that "[i]f either Gansu QLS or the Wuxi Company utilizes such intellectual properties on the reformation of other strains,
it shall pay royalty fees to the other party and the research and development achievements from such reformation activities shall
be jointly owned by both parties." Please tell us whether the obligation to pay royalty fees to the other party is still in
effect even though the cooperation agreement has expired, and please disclose whether any material intellectual properties are
jointly owned with the Wuxi Company, and, if so, what affect this could have on the company's business.

Response: The Company respectfully
informs the Staff that no intellectual property was developed under the cooperation agreement between Gansu QLS and the Wuxi Company.
Thus, there is no obligation on either party to pay royalty fees to the other party.

Principal Shareholders, page 96

5. We note your revised disclosure on
page 96 that following the completion of this offering, your directors and executive officers will hold 61.67% of the issued and
outstanding ordinary shares. Please revise your prospectus summary to disclose that your directors and executive officers will
hold 61.67% of the issued and outstanding ordinary shares and add a risk factor that addresses the risks associated with the concentration
of your beneficial ownership among your directors and executive officers.

Response: In response to the Staff’s
comment, the Company updated its disclosure on page 19 of Amendment No.1 to include a risk factor that addresses the risks associated
with the concentration of the Company’s beneficial ownership among its directors and executive officers. The Company also
updated its disclosure in the prospectus summary section on page 7 of Amendment No.1.

Exhibit Index, page 129

6. Please have counsel revise Exhibit
5.1 to provide an opinion of legality regarding the ordinary shares underlying the underwriter's warrants.

Response: In response to the Staff’s
comment, Ogier, the Company’s counsel with respect to the laws of the Cayman Islands, updated its opinion letter to include
an opinion of legality regarding the ordinary shares underlying the underwriter's warrants.

Report of Independent Registered
Public Accounting Firm, page F-1

7. We note your amended audit report
has revised the dates for notes 11 and 13 to November 1, 2019 for your recent reverse stock split and other transactions. We also
note that note 14 for subsequent events still remains dated September 6, 2019. Please confirm that your auditors will file a revised
consent and audit report to also update the subsequent events footnote prior to filing effectiveness.

Response: In response to the Staff’s
comment, the Company filed an updated consent and audit report with Amendment No.1.

We thank the Staff for its review of the
foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Ying Li at yli@htflawyers.com
or by telephone at 212-530-2206.

    Very truly yours,

    /s/ Zhanchang Xin

    Zhanchang Xin

    CEO

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC