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January 29, 2024
Zihao Liu
Chief Financial Officer
Meiwu Technology Company Limited
1602, Building C, Shenye Century Industrial Center
No. 743 Zhoushi Road , Hangcheng Street
Bao’an District
Shenzhen, People’s Republic of China
Re:Meiwu Technology Company Limited
Amendment No. 2 to Form 20-F for Fiscal Year Ended December 31, 2022
File No. 001-39803
Dear Zihao Liu:
            We have reviewed your December 27, 2023 response to our comment letter and have the
following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our November 20, 2023
letter.
Amendment No. 2 to Form 20-F
Item 3. Key Information
Our Corporate Structure, page 3
1.We note the structure charts you added in response to comment 4. Please provide your
proposed revised disclosure that adds a footnote to disclose the 40% ownership of Heme
Yulin.

 FirstName LastNameZihao Liu
 Comapany NameMeiwu Technology Company Limited
 January 29, 2024 Page 2
 FirstName LastName
Zihao Liu
Meiwu Technology Company Limited
January 29, 2024
Page 2
Permission or Approval Required from the PRC Authorities for the VIE's Operations, page 9
2.We note your response and revised disclosure in response to prior comment 5. With
respect to your PRC counsel, we note your revised disclosure "as confirmed by our PRC
counsel, Dacheng ... ." If true, please provide your proposed revised disclosure that states
that you relied on the "opinion" of counsel. Please make the same changes to your
disclosure in response to prior comment 8 as well. Additionally, with respect to the
uncertainty and consequences of any future actions of the PRC government, please
provide your proposed revised disclosure to include the risk and related consequences if
you do not receive or maintain such permissions or approvals. In this light, we point you
to our original comment 8 in the comment letter dated August 11, 2023, to " ... please
revise to describe the consequences to you and your investors if you, your subsidiaries, or
the VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such permissions or approvals are not required, or (iii) applicable laws,
regulations, or interpretations change and you are required to obtain such permissions or
approvals in the future." (Emphasis added).
Selected Condensed Consolidated Financial Schedule of Meiwu Technology Company Limited,
its subsidiaries and the VIE, page 54
3.We note your revisions in response to comment 9. Please confirm that your annual report
for the year ended December 31, 2023 will include similar revisions in your Consolidation
of Variable Interest Entity disclosure in Note 3 to your financial statements.
Notes to Consolidated Financial Statements
Note 12. Equity, page F-29
4.We note your response to comment 12. Please revise your disclosure of the $9.6 million of
consideration to be delivered to the sellers in the Yuanxing acquisition on December 12,
2022 to reconcile with the $2,640,000 acquisition purchase price for the issuance of 12
million ordinary shares disclosed in Note 4.
            Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Cara Wirth at 202-551-7127 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services