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September 19, 2023
Xin Wang
People’s Republic of China
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Registration Statement on Form F-3
Filed August 24, 2023
File No. 333-274194
Dear Xin Wang:
            We have limited our review of your registration statement to those issues we have
addressed in our 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.

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 2
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 2
Registration Statement on Form F-3, filed August 24, 2023
Cover Page
1.We note your statement on the cover page that "Meihua faces various legal and
operational risks and uncertainties as a company with its principal subsidiaries based in
and primarily operating in China." Please expand on this disclosure to state whether these
risks could result in a material change in your operations and/or the value of your
securities or could significantly limit or completely hinder your ability to offer securities
to investors and cause the value of your securities to significantly decline or be worthless.
Your disclosure should address how recent statements and regulatory actions by China’s
government, such as those related to the use of variable interest entities and data security
or anti-monopoly concerns, have or may impact the company’s ability to conduct its
business, accept foreign investments, or list on a U.S. or other foreign exchange.
2.We note your disclosure in the prospectus summary on page 1 that "[t]he securities
offered in this prospectus are the securities of Meihua International, an exempted
company which was incorporated under the laws of the Cayman Islands." Please include
similar disclosure on the cover page of the prospectus.
3.We note your description of how cash is transferred through your organization. Please
revise to disclose your intentions to distribute earnings. State whether any transfers,
dividends, or distributions have been made to date between the holding company, its
subsidiaries, or to investors, and quantify the amounts where applicable. Provide a cross-
reference to the consolidated financial statements.
Commonly Used Defined Terms, page iii
4.We note your statement that "“China” or the “PRC” refers to the People’s Republic of
China, including the special administrative regions of Hong Kong and Macau, and only
when this prospectus refers to specific laws and regulations adopted by the PRC and the
discretion of China governmental authorities, reference to “China” or the “PRC” excludes
Taiwan and the special administrative regions of Hong Kong and Macau." Please clarify
that the legal and operational risks associated with operating in China discussed elsewhere
in the prospectus also apply to operations in Hong Kong and Macau.
Prospectus Summary, page 1
5.Please revise to quantify dividends or distributions made to U.S. investors, the source, and
their tax consequences or state that no dividends have been made to date.
Key Information Related to Doing Business in China
Risks and Uncertainties Related to Doing Business in China, page 2
6.We note certain differences between your disclosure appearing in the "Key Information
Related to Doing Business in China" and "Risk Factor" sections of your prospectus as

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 3
 FirstName LastNameXin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 3
compared to the disclosure appearing in your Amended Annual Report on Form 20-F filed
on August 29, 2023 relating to legal and operational risks associated with operating in
China and PRC regulations. As noted in our comment letter to your Amended Annual
Report dated August 25, 2023, it is unclear to us that there were recent changes in the
regulatory environment in the PRC warranting revised disclosure to mitigate the
challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may
intervene in or influence your operations at any time, or may exert control over operations
of your business, which could result in a material change in your operations and/or the
value of the securities you have registered for sale. We remind you that, pursuant to
federal securities rules, the term “control” (including the terms “controlling,” “controlled
by,” and “under common control with”) as defined in Securities Act Rule 405 means “the
possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and regulations in China
can change quickly with little advance notice. Because the disclosure in your
prospectus has removed references to PRC laws being inconsistent and unpredictable, the
PRC government’s power to exercise significant oversight and discretion over the conduct
of your business, the fact that the regulations to which you are subject may change rapidly
and with little notice, and the level of government involvement in the Chinese
economy, we do not believe that your revised disclosure conveys these risks. We also note
your language in your risk factor captioned "We may not be able to prevent others from
the unauthorized use of our intellectual property, which could materially harm our
business and competitive position" noting that you may not be able to effectively protect
your intellectual property rights or to enforce your contractual rights in China “or in other
jurisdictions.” However, you disclose that Meihua is not a Chinese operating company but
a Cayman Islands holding company with all operations conducted by its subsidiaries
located in mainland China. Please revise your disclosures in these areas to be consistent
with the corresponding disclosures as they exist in your Amended Annual Report as of
August 29, 2023.
Incorporation of Documents by Reference, page 40
7.Please updated your Incorporation of Documents by Reference section to refer to your
most recent amendment to your Annual Report on Form 20-F which was filed on August
29, 2023.
Signatures, page II-4
8.We note that the signatures for your three directors have been provided by your Chief
Executive Officer acting as their attorney-in-fact. However, you have not included a
signed power of attorney as an exhibit to the Registration Statement. When you file your
next amendment to the Registration Statement, please include signatures for these

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 4
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 4
directors signed in their own capacity or include signed powers of attorney as
exhibits. Please refer to Item 601(b)(24) of Regulation S-K.
            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 Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-
7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.