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MingZhu Logistics Holdings Limited

27F, Yantian Modern Industry Service Center

No. 3018 Shayan Road, Yantian District

Shenzhen, Guangdong, China 518081

VIA EDGAR

May 7, 2020

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, NE

Washington, D.C. 20549

Attn: Karina Dorin

    Re:

        MingZhu Logistics Holdings Limited

        Amendment No. 4 to

        Registration Statement on Form F-1

        Filed April 23, 2020

        File No. 333-233992

Dear Ms. Dorin:

MingZhu Logistics Holdings
Limited (the “Company” or “we”) hereby transmits its response to the comment letter received
from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
dated April 30, 2020, regarding the Company’s Amendment No. 4 to Registration Statement on Form F-1 (the “Registration
Statement”) filed on April 23, 2020. For the Staff’s convenience, we have repeated below the Staff’s comments
in bold, and have followed each comment with the Company’s response.

Form F-1/A filed April 23, 2020

Risk Factors, page 8

 1. Please revise to provide risk factor disclosure regarding the limited ability of U.S. regulators
to conduct investigations and inspections within China.

In response to the Staff’s
comment, we will add the following risk factor in an amended Registration Statement.

There are uncertainties under
the PRC laws relating to the procedures and time requirement for the U.S. regulators to bring about investigations and evidence
collection within the territory of the PRC.

On December 28, 2019, the newly
amended Securities Law of the PRC (the “PRC Securities Law”) was officially promulgated, which became effective on
March 1, 2020. According to Article 177 of the PRC Securities Law (the “Article 177”), the securities regulatory authority
of the State Council may establish a regulatory cooperation mechanism with the securities regulatory authorities of another country
or region to implement cross-border supervision and administration. Article 177 further provides that overseas securities regulatory
authorities may not carry out investigations and evidence collection directly within the territory of the PRC, and that no Chinese
entity or individual is allowed to provide any documents or materials related to securities business activities to overseas agencies
without prior consent of the securities regulatory authority of the State Council and the competent departments of the State Council.
Moreover, the Civil Procedure Law of the PRC, promulgated in 1991 and last amended in 2017, provides that except for the request
for and provision of judicial assistance in accordance with international treaties concluded or participated by the PRC, or via
diplomatic channels, no foreign agency or individual may, without the consent of the competent authorities of the PRC, carry out
investigation or collect evidence within the territory of the PRC.

Page
2

Our PRC Counsel is of the understanding
that (i) the Article 177 is applicable in the circumstances related to direct investigation or evidence collection conducted by
overseas authorities within the territory of the PRC (in such case, the foregoing activities are required to be conducted through
collaboration with or by obtaining prior consent of competent PRC authorities); (ii) the Article 177 does not limit or prohibit
the Company, as a company duly incorporated in Cayman Islands and to be listed on Nasdaq, from providing the required documents
or information to NASDAQ pursuant to applicable listing rules and U.S. securities laws; and (iii) as of the date of this prospectus,
they are not aware of any implementing rules or regulations which have been published regarding application of the Article 177.

Our principal business operation
is conducted in the PRC. In the event that the U.S. regulators carry out investigation on us and there is a need to conduct investigation
or collect evidence within the territory of the PRC, the U.S. regulators may not be able to carry out the investigation or evidence
collection directly in the PRC under the PRC laws. The U.S. regulators may consider cross-border cooperation with securities regulatory
authority of the PRC by way of judicial assistance, diplomatic channels or regulatory cooperation mechanism established with the
securities regulatory authority of the PRC. However, there is no assurance that the U.S. regulators could succeed in establishing
such cross-border cooperation in a specific case or could establish the cooperation in a timely manner.

Furthermore, as the Article 177
is relatively new and there is no implementing rules or regulations which have been published regarding application of the Article
177, it remains unclear how the law will be interpreted, implemented or applied by the Chinese Securities Regulatory Commission
or other relevant government authorities. As such, there are uncertainties as to the procedures and time requirement for the U.S.
regulators to bring about investigations and evidence collection within the territory of the PRC. If U.S. regulators are unable
to conduct such investigations, such U.S. regulators may determine to suspend and ultimately delist our ordinary shares from the
Nasdaq Capital Market or choose to suspend or de-register our SEC registration.

We thank the Staff for
its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact our counsel
Jonathan Deblinger, Esq. of Ellenoff Grossman & Schole LLP by email at jdeblinger@egsllp.com or by telephone at (212)
370-1300.

    Sincerely,

    /s/ Jinlong Yang

        Jinlong Yang

        Chief Executive Officer

    cc:
    Jonathan Deblinger

    Ellenoff Grossman & Schole LLP