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 July 29, 2025

Yunwu Li
Chief Executive Officer
CDT Environmental Technology Investment Holdings Limited
C1, 4th Floor, Building 1, Financial Base, No. 8 Kefa Road
Nanshan District, Shenzhen, China 518057

 Re: CDT Environmental Technology Investment Holdings Limited
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed May 15, 2025
 File No. 001-42007
Dear Yunwu Li:

 We have reviewed your filing and have the following comments.

 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.

Form 20-F for the Fiscal Year ended December 31, 2024
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

1. We note that the audit report on page F-2 indicates the audits were
conducted in
 accordance with the standards of the PCAOB though also in accordance
with auditing
 standards generally accepted in the United States of America.

 Please discuss this language with Enrome LLP, as the reference to
auditing standards
 generally accepted in the United States of America is no longer
appropriate or
 necessary. This was addressed in our Commission Guidance Regarding the
Public
 Company Accounting Oversight Board's Auditing and Related Professional
Practice
 Standard No. 1 (Release Nos. 33-8422; 34-49708; FR-73), effective May
14, 2004.

 Please obtain and file a revised audit opinion from the auditor that
adheres to the
 guidance in PCAOB Auditing Standard 3101, including paragraph 09(c).
 July 29, 2025
Page 2

Note 4 - Accounts receivable, net, page F-21

2. We note your comparison of "days sales outstanding" on page 68,
indicating an
 increase to 455 for 2024, from 262 in 2023, and details regarding the
allowance for
 credit losses on page F-11, indicating an increase to $9.3 million at
the end of 2024
 from about $3.0 million a year earlier. We also note that your allowance
is about 31%
 of 2024 revenues of $29.8 million, and that you have disclosure on page
67 explaining
 that a $23.1 million increase in accounts receivable during 2024 was
"primarily due to
 a longer collection cycle" which you attribute to "delays in the
government billing
 approval process" resulting from economic downturn in the PRC.

 Please provide us with further details regarding the activity reflected
in the accounts
 receivable balance reported on page F-3, showing an increase of 55%
compared to the
 end of the prior year, and resulting in a balance that is 152% of total
revenues for the
 year. For example, clarify the extent of any material concentrations
related to specific
 customers or groups of customers and describe any irregularity in the
pattern of
 accumulating balances over the course of the year. Also provide us with
an accounts
 receivable aging schedule as of December 31, 2024, delineated between
the
 government and non-government customers.

 Please explain to us how you applied FASB ASC 606-10, subparagraphs
25-1(e), 55-
 3A through 55-3C, and 25-5 through 25-7, in assessing the probability
that you would
 collect substantially all of the consideration to which you were
entitled under the
 contracts with customers, in determining that all criteria for initial
recognition had
 been met, and if this can be shown, also explain how you considered the
delays in
 collection in concluding that year-end balances were recoverable.

3. We note your disclosure on page 69 regarding the aging method applied in
 determining your allowance for doubtful accounts, explaining that you
apply
 "incremental ratios" of 15%, 25%, and 100% of accounts having
outstanding balances
 aged between 270 days and one year, one year and two years, and beyond
two years,
 respectively. Please explain to us how you developed these default rates
and clarify
 whether the policy is uniformly applied to all customer classes and, if
this is the case,
 also explain to us how you assessed the credit risk profiles of the
various customer
 groups in determining that a uniform rate for all customers would be
appropriate.

Exhibits

4. We note that you list certifications for Exhibits 12.1, 12.2, 13.1 and
13.2 and indicate
 these were furnished with the report, although this does not appear to
be the
 case. Please amend your filing to include the certifications prescribed
in paragraphs
 12 and 13 of the Instructions As To Exhibits for Item 19 of Form 20-F.
Please ensure
 that the certifications refer to the appropriate filing and are
currently dated.
 July 29, 2025
Page 3

 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.

 Please contact Yolanda Guobadia at 202-551-3562 or Robert Babula at
202-551-3339
if you have questions regarding comments.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Clayton Parker
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