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 June 12, 2025

Jingwei Zhang
Chief Financial Officer
MingZhu Logistics Holdings Ltd
27F, Yantian Modern Industry Service Center
No. 3018 Shayan Road, Yantian District
Shenzhen, Guangdong, China 518081

 Re: MingZhu Logistics Holdings Ltd
 Registration Statement on Form F-3
 Filed May 23, 2025
 File No. 333-287552
Dear Jingwei Zhang:

 We have conducted a limited review of your registration statement and
have the
following comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Registration Statement on Form F-3
Risk Factors, page 18

1. We note the significant number of shares the selling shareholders may be
offering.
 Please revise to include risk factor disclosure discussing the impact
that this offering
 could have on your stock price and on investors.
The trading price of our ordinary shares may be volatile, which could result is
substantial
losses, page 56

2. You disclose that the trading price of your securities may be volatile
and could
 fluctuate widely due to factors beyond your control. You further discuss
that this may
 happen because of the broad market and industry factors, like the
performance and
 fluctuation of the market prices of other companies with business
operations located
 June 12, 2025
Page 2

 mainly in China that have listed their securities in the United States
and attitudes of
 investors toward Chinese companies listed in the United States in
general. Please
 also revise to address the potential for rapid and substantial decreases
in your stock
 price, including decreases unrelated to your operating performance or
prospects. Your
 disclosure should include intra-day stock price range information and
should cover a
 period of time sufficient to demonstrate the recent price volatility and
should address
 the impact on investors. To the extent recent increases in your stock
price are
 significantly inconsistent with improvements in actual or expected
operating
 performance, financial condition or other indicators of value, discuss
the
 inconsistencies and where relevant quantify them. If you lack
information to do so,
 explain why.
 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.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Claudia Rios at 202-551-8770 or Kevin Dougherty at
202-551-3271
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Joan Wu, Esq.
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