SecProbe.io

March 3, 2020
Andreas Spiegler
Chairman and Chief Executive Officer
Industrial Technical Holdings Corporation
Huanxiu Street Office, Shuanglong Industrial Park
266201 Jimo
Qingdao, China
Re:Industrial Technical Holdings Corporation
Amendment No. 3 to Registration Statement on Form F-1
Filed February 24, 2020
File No. 333-233613
Dear Mr. Spiegler:
            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.  Unless we note
otherwise, our references to prior comments are to comments in our February 4, 2020 letter.
Amendment No. 3 to Registration Statement on Form F-1 filed February 24, 2020
Six Months Ended June 30, 2019, page 74
1.Please reconcile your response to prior comment 1 regarding the sales of baler machines
in June 2019 with your disclosure here regarding no new products.
Ordinary Shares, page 107
2.Please expand your revisions in response to prior comment 6 to clarify whether the
indemnification and hold harmless provisions cited in your disclosure applies to liabilities
under the federal securities laws.

 FirstName LastNameAndreas  Spiegler
 Comapany NameIndustrial Technical Holdings Corporation
 March 3, 2020 Page 2
 FirstName LastName
Andreas  Spiegler
Industrial Technical Holdings Corporation
March 3, 2020
Page 2
Related Party Transactions, page 108
3.We note your response to prior comment 7.  Please clarify how an "Advance for
operations" generates an amount that is due to you from your officers.  Also disclose the
interest rate and date that each of the advances mentioned in this section must be repaid.
Item 8. Exhibits and Financial Statement Schedules
Consent of independent accounting firm Centurion ZD CPA & Co. , page 115
4.Please have your accounting firm provide an updated consent.
Signatures, page 117
5.We note your response to prior comment 8.  However, Form F-1 must be signed by both
your principal accounting officer and your principal financial officer.  Please revise below
the second paragraph of text required on the Signatures page to indicate who signed your
registration statement in each of these capacities.
Exhibits
6.We note your response to prior comment 2.  Please file each counsel's consent expressly
stating that counsel consents to the summarization of its opinion as you have done in your
prospectus.  Also, please reconcile the names of your subsidiaries in exhibits 5.2, 5.3 and
5.4 with your disclosure on page 5.
7.Please file the leases expiring in 2021 mentioned in your revisions on page 78.
            You may contact Michael Fay at 202-551-3812 or Brian Cascio, Accounting Branch
Chief, at 202-551-3676 if you have questions regarding comments on the financial statements
and related matters.  Please contact Geoffrey Kruczek at 202-551-3641 or Russell Mancuso at
202-551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Andrew J. Befumo, Esq.