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Meihua International
Medical Technologies Co., Ltd.

88 Tongda Road, Touqiao Town

Guangling District, Yangzhou, 225000

People’s Republic of China

July 3, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Attn:
    Mr. Conlon Danberg

    Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Annual Report on Form 20-F

    Filed April 14, 2023

    File No. 001-41291

Ladies and Gentlemen:

We are hereby transmitting
the response of Meihua International Medical Technologies Co., Ltd., a Cayman company (the “Company,” “we,”
or “our”), to the comment letter we received from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) on June 21, 2023 regarding the Company’s Annual
Report on Form 20-F filed with the Commission on April 14, 2023 (the “Form 20-F”). An amendment to the Form
20-F (the “Amended Form 20-F”) addressing the Staff’s comments is being submitted to the Commission concurrently
with this letter.

For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.

Annual Report on Form 20-F, filed April
14, 2023

Introductory Notes

Use of Certain Defined Terms, page ii

1. We note your defined term “China”
excludes “Taiwan and the special administrative regions of Hong Kong and Macau for the purposes of this report only.” Please
clarify that the legal and operational risks associated with operating in China discussed elsewhere in the annual report also apply to
operations in Hong Kong and Macau.

Response: In response to the Staff’s
comment, the Company revised its defined term “China” and deleted the language “excluding Taiwan and the special administrative
regions of Hong Kong and Macau for the purposes of this report only” but added that “and only when this report refers to specific
laws and regulations adopted by the PRC and discretion of China governmental authorities, excludes Taiwan and the special administrative
regions of Hong Kong and Macau” on page ii. The Company also added a disclosure on page 1 stating that “in addition, all the
operational risks associated with being based in and having operations in mainland China as discussed in this “Item 3. Key Information—D.
Risk Factors—Risks Related to Our Business and Industry” also apply to operations in the Hong Kong Special Administrative
Region. With respect to the legal risks associated with being based in and having operations in mainland China as discussed in risk factors
under “Item 3. Key Information—D. Risk Factors—Risks Related to Our Corporate Structure” and “Item 3. Key
Information—D. Risk Factors—Risks Related to Doing Business in China,” the laws, regulations and discretion of mainland
China governmental authorities discussed in this annual report are expected to apply to mainland China entities and businesses only, rather
than entities or businesses in the Hong Kong Special Administrative Region which operates under a different set of laws from mainland
China.”

In addition, the Company respectfully advises
the Staff that the proposed disclosure does not include Macau and Taiwan as the Company does not have operations in Macau or Taiwan.

Item 3. Key Information, page 1

2. At the onset of Item 3, please disclose
prominently that you are not a Chinese operating company but a Cayman Islands holding company with operations conducted by your subsidiaries.
In addition, please provide early in the Key Information section a diagram of the company’s corporate structure.

Response: In response to the Staff’s
comment, the Company added a disclosure that it is not a Chinese operating company but a Cayman Islands holding company with operations
conducted by its subsidiaries located in mainland China. In addition, the Company also provided its corporate structure on page 1 under
“Item 3. Key Information” in the Amended Form 20-F.

3. At the onset of Item 3, please provide prominent
disclosure about the legal and operational risks associated with being based in or having the majority of the company’s operations
in China. Your disclosure should make clear 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 or continue to offer securities to investors
and cause the value of such 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 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.

Response: In response to the Staff’s comment, the Company summarized and
consolidated its disclosure of the risks related to its operations in China, including the disclosure noted in the Staff’s comment,
under “Item 3. Key Information” under the heading “Key Information Related to Doing Business in China—Risks and
Uncertainties Related to Doing Business in China” on page 4 of the Amended Form 20-F.

4. At the onset of Item 3, please disclose
the location of your auditor’s headquarters and whether and how the Holding Foreign Companies Accountable Act, as amended by the
Consolidated Appropriations Act, 2023, and related regulations will affect your company.

Response: In response to the Staff’s comment, the Company added disclosure
under Item 3 regarding the location of the Company’s auditor’s headquarters and how the Holding Foreign Companies Accountable
Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations would affect the Company on page 5 of the Amended
Form 20-F.

5. Please clearly disclose how you will refer
to the holding company and subsidiaries when providing the disclosure throughout the document so that it is clear to investors which entity
the disclosure is referencing and which subsidiaries or entities are conducting the business operations. For example, please disclose,
if true, that your subsidiaries conduct operations in China. In this regard, we note your disclosure on page ii that “we,”
“us,” “our company,” “our,” “the Company,” and “Meihua International” may
refer to various entities, including your PRC operating subsidiaries, depending on the context.

Response: In response to the Staff’s
comment, the Company added disclosure under Item 3 to disclose how we will refer to the holding company and subsidiaries when providing
the disclosure throughout the document.

6. At the onset of Item 3, please provide a
clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings. Quantify any
cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and direction of
transfer. Quantify any dividends or distributions that a subsidiary have made to the holding company and which entity made such transfer,
and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign
exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations
on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

Response: In response to the Staff’s
comment, the Company added disclosure under Item 3 under the heading “Cash Flows through Our Company” to describe how cash
is transferred through our organization and our intentions to distribute earnings on page 3 of the Amended Form 20-F. The Company also
quantified cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, as well
as the direction of such transfers, and confirmed that no dividends or distributions have been made to any investors during the reporting
period. In addition, the Company further described any restrictions on foreign exchange and our ability to transfer cash between entities,
across borders, and to U.S. investors.

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7. At the onset of Item 3, please disclose
each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer securities to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the China
Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is required to
approve your operations, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions
or approvals have been denied. Please also describe the consequences to you and your investors if you or your subsidiaries: (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.

Response: In response to the Staff’s
comment, the Company added a disclosure under Item 3 under the headings “Permissions and Approvals Required to be Obtained from
PRC Authorities for our Business Operations” and “Permissions and Approvals Required to be Obtained from PRC Authorities for
our Securities Offerings” on page 5 of the Amended Form 20-F.

8. At the onset of Item 3, please disclose
the risks that your corporate structure and being based in or having the majority of the company’s operations in China poses to
investors. In particular, describe the significant regulatory, liquidity, and enforcement risks. For example, specifically discuss risks
arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations
in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations
at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could
result in a material change in your operations and/or the value of your securities. Acknowledge any risks that any actions by the Chinese
government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers
could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value
of your securities to significantly decline or be worthless.

Response: In response to the Staff’s comment, the Company summarized and
consolidated its disclosure of the risks related to operations in China, including the disclosure noted in the Staff’s comment,
under “Item 3. Key Information” under the heading “Key Information Related to Doing Business in China—Risks and
Uncertainties Related to Doing Business in China” on page 4 of the Amended Form 20-F.

9. Please revise your disclosure to include
in Item 3 a separate “Enforceability of Civil Liability” section regarding the ability to impose liability on officers and directors
located in Hong Kong and China (or elsewhere outside of the U.S., if applicable). This disclosure should be consistent with your risk
factor disclosure under the captions “Certain judgments obtained against us by our shareholders may not be enforceable.” on
page 14 and “You may experience difficulties in effecting service of legal process, enforcing foreign judgments or bringing actions
in the PRC against us or our management named in the report based on foreign laws.” on page 17.

Response: In response to the Staff’s comment, the Company revised and added
a separate section entitled “Enforceability of Civil Liability” under Item 3 on page 6 of the Amended Form 20-F.

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Risk Factors

Risks Related to Our Corporate Structure

Certain judgments obtained against us by our shareholders may
not be enforceable, page 14

10. We note your statement that your current
officers “are nationals and residents of countries other than the United States.” Please expand on this risk factor to (i) reference
your current directors in addition to your current officers and (ii) note the specific countries in which they reside. For example, if
true, please state that your directors and officers are located in the PRC and, as such, it will be even more difficult to enforce liabilities
against them or against any directors and officers located outside of the U.S.

Response: In response to the Staff’s
comment, the Company revised the risk factor to state that our directors and officers are located in the PRC and, as such, it will be
difficult to enforce liabilities against them or against any directors and officers located in the PRC on page 20 of the Amended Form
20-F.

We thank the Staff in advance
for its review of the foregoing in relation to the Company’s filing of its Amended Form 20-F. Should you have any questions or concerns,
please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104.

    Sincerely,

    /s/ Xin Wang

    Xin Wang

    Chief Executive Officer

    Meihua International Medical Technologies Co., Ltd.

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