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August 17, 2023
Zheng Xu
Chief Executive Officer
Missfresh Ltd
3rd Floor, Block A, Vanke Times Center
No. 9 Wangjing Street
Chaoyang District, Beijing 100016
The People’s Republic of China
Re:Missfresh Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-40529
Dear Zheng Xu:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 140
1.We note your statement that you reviewed the Company’s register of members as well as
the Schedule 13Gs and the amendments thereto filed by major shareholders in connection
with your required submission under paragraph (a). Please supplementally describe any
additional materials that were reviewed and tell us whether you relied upon any legal
opinions or third party certifications such as affidavits as the basis for your submission. In
your response, please provide a similarly detailed discussion of the materials reviewed and
legal opinions or third party certifications relied upon in connection with the required
disclosures under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For

 FirstName LastNameZheng Xu
 Comapany NameMissfresh Ltd
 August 17, 2023 Page 2
 FirstName LastName
Zheng Xu
Missfresh Ltd
August 17, 2023
Page 2
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note that your disclosures pursuant to Items 16I(b)(2) and (b)(3) are provided for
Missfresh Limited.  We also note that your disclosures on Exhibit 8.1 that indicate that
you have consolidated foreign operating entities in Hong Kong, Cayman Islands, British
Virgin Islands, and the People’s Republic of China.  Please note that Item 16I(b) requires
that you provide disclosures for yourself and your consolidated foreign operating entities,
including variable interest entities or similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and confirm, if
true, that you have disclosed the percentage of your shares or the shares of your
consolidated operating entities owned by governmental entities in each foreign
jurisdiction in which you have consolidated operating entities.  Alternatively, provide
this information in your supplemental response.
•With respect to (b)(3), please provide the information required by (b)(3) for you and
all of your consolidated foreign operating entities in your supplemental response.
            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 Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Shu Du