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April 21, 2023
Jinlong Yang
Chief Executive Officer
MingZhu Logistics Holdings Limited
27F, Yantian Modern Industry Service Center
No. 3018 Shayan Road, Yantian District
Shenzhen, Guangdong, China 518081
Re:MingZhu Logistics Holdings Limited
Amendment No. 3 to Registration Statement on Form F-3
Filed April 10, 2023
File No. 333-267839
Dear Jinlong Yang:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Form F-3
Cover Page
1.We note your disclosure regarding your auditor’s participating firm Da Hua CPA.  Please
disclose the location of the headquarters of such participating firm.
About MingZhu Logistics Holdings Limited, page 1
2.We note your disclosure on page 19 that on June 22, 2021, the U.S. Senate passed the
Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would
amend the HFCAA and require the SEC to prohibit an issuer’s securities from trading on
any U.S. stock exchanges if its auditor is not subject to PCAOB inspections for two
consecutive years instead of three, and thus, would reduce the time before your securities

 FirstName LastNameJinlong Yang
 Comapany NameMingZhu Logistics Holdings Limited
 April 21, 2023 Page 2
 FirstName LastName
Jinlong Yang
MingZhu Logistics Holdings Limited
April 21, 2023
Page 2
may be prohibited from trading or delisted.  Please update such disclosure to disclose that
trading in your securities may be prohibited under the Holding Foreign Companies
Accountable Act, as amended by the Consolidated Appropriations Act, 2023, and related
regulations if the PCAOB determines that it cannot inspect or investigate completely your
auditor for a period of two consecutive years, and that as a result an exchange may
determine to delist your securities.  Please also update your related risk factor disclosure
on page 43 that similarly makes reference to the Accelerating Holding Foreign Companies
Accountable Act.
General
3.We note your disclosure regarding the recently published Trial Administrative Measures
that impose certain filing requirements for direct and indirect overseas listings and
offerings.  Please disclose whether you will comply with the CSRC review process.
4.Please revise to incorporate by reference all amendments to your Form 20-F for the fiscal
year ended December 31, 2021.
            Please contact Karina Dorin, Staff Attorney, at (202) 551-3763 or Laura Nicholson,
Special Counsel, at (202) 551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Bill Huo