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CORRESP
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CORRESP

 1900 K Street NW

 Washington DC, 20006-1110

+1 202 261 3300 Main

 +1 202 261 3333 Fax

www.dechert.com

 DEVON ROBERSON

 devon.roberson@dechert.com

+1 202 261 3477 Direct

 March 24, 2023

VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission

100 F Street, NE

 Washington, DC
20549

Re:
 Harbor ETF Trust (the “Registrant”)

Post-Effective Amendment No. 24

(File Nos. 333-255884 and 811-23661)

Ladies and Gentlemen:

 This
correspondence is being filed for the purpose of responding to comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided by Ms. Rebecca Marquigny of the Division of Investment
Management with respect to Post-Effective Amendment (“PEA”) No. 24 to the Registrant’s registration statement on Form N-1A. PEA No. 24 was filed in connection with the launch of a new
series of the Registrant, Harbor Small Cap Explorer ETF (the “Fund”).

 Set forth below are the Staff’s verbal comments
together with the Registrant’s responses. Terms used but not defined herein have the same meaning as in PEA No. 24.

COMMENT 1:

(Prospectus)

 Per the format shown in Item 3 of Form N-1A, please present the second sentence of the preamble to
the fee table in bold font.

Response:

The Registrant confirms that it will present the second sentence of the preamble to the fee table in bold font.

 March 24, 2023

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 2

COMMENT 2:

(Prospectus)

 Please provide the Staff with a completed fee table and expense example. Please also confirm that any blank or bracketed information will be
finalized in the Fund’s 485(b) filing and provide a copy of the final materials.

Response:

A completed fee table and expense example are included in Attachment 1 to this letter and information about the Fund’s Subadvisors is included in response to comments below. The Registrant confirms that it will include complete
information in its 485(b) filing.

COMMENT 3:

(Prospectus)

 Regarding the second footnote to the fee table, please supplementally explain how the Registrant estimated other expenses and determined the
estimate was reasonable.

Response:

Pursuant to Instruction 6(a) to Item 3 of Form N-1A, the Fund has estimated the “Other Expenses” it expects to incur during the fiscal year. In determining its estimated
expenses, the Fund considered that pursuant to the investment advisory agreement, the Adviser pays all of the operating expenses of the Fund, with limited exclusions. The Fund believes it is unlikely to incur any of the excluded expenses during the
fiscal year. Therefore, its estimated “Other Expenses” are 0.00%.

COMMENT 4:

(Prospectus)

 Please modify the preamble to the expense example to indicate whether the impact of the reimbursement arrangement is reflected, and if so,
for how long.

Response:

The Registrant respectfully notes that there is no expense reimbursement arrangement in place between the Fund and the Adviser. Rather, the Adviser bears the operating expenses of the Fund, with limited exclusions, in accordance
with the unitary fee structure. Therefore, the Registrant has made no changes in response to this comment.

COMMENT 5:

(Prospectus)

 As written, the strategy disclosure does not inform investors how the Fund’s portfolio is constructed or its investments are selected.
At some points, the strategy seems contradictory – suggesting that the Adviser will implement model portfolios in its discretion while also saying the Adviser does not expect to independently identify securities for the Fund. Please revise to
clarify the strategy overall, as well as the roles played by the Adviser and subadvisers in implementing the strategy.

 March 24, 2023

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 3

Response:

 The Registrant believes that it is not contradictory to state that the Adviser will implement model portfolios in its discretion and that the
Adviser does not expect to independently identify securities for the Fund. While the Adviser may exercise its discretion in declining to implement, or partially implementing, a model portfolio decision, it does not expect to identify securities for
the Fund’s portfolio other than through use of the model portfolios. The Registrant has revised its disclosure as follows to improve the clarity of the discussion of its strategy:

 “The Fund employs a multi-manager approach to achieve its investment objective. The
Fund’s investment adviser, Harbor Capital Advisors, Inc. (the “Advisor”) is responsible for selecting and overseeing investment subadvisers (each, a “Subadvisor”) for the Fund. The Advisor does not expect to
independently identify securities for investment for the Fund. Instead, Eacheach Subadvisor is responsible for providing the Advisor with a model portfolio, which the Advisor will implement in its discretion in
managing the Fund. The Advisor is solely responsible for allocating the Fund’s assets among each Subadviser’s
strategy as well as implementing each strategy, (which includes buying and selling securities as recommended by each Subadvisor). The Adviser does not
expect to independently identify securities for investment for the Fund. The Advisor in its discretion may decline to implement a Subadvisor’s recommendations under certain circumstances,
including when the recommended securities are not available in the specific quantities or prices sought by the Subadvisor or when purchasing such securities in conjunction with the Fund’s existing holdings would violate an investment
restriction of the Fund.

 The Advisor is responsible for determining
the allocation of the Fund’s assets among each Subadvisor’s strategy. The Advisor will adjust those allocations over time based upon its qualitative and quantitative assessment of each strategy and how those strategies work in
combination to produce what the Adviser believes is an enhanced risk-adjusted investment outcome for the Fund idiosyncratic alpha (i.e. returns resulting from stock selection) compounding
over time. Under normal circumstances, the Advisor expects to review the allocations to each Subadvisor’s strategy quarterly.”

COMMENT 6:

(Prospectus)

 Please clarify who has responsibility for individual portfolio holding decisions at the transaction level. Sometimes, the disclosure suggests
the Adviser manages asset allocation across the models. In other places, it sounds like the Adviser uses the recommended model portfolio as a list of eligible investment objects from which it may pick. Please revise for clarity.

Response:

The Adviser retains the sole authority to buy and sell securities for the Fund’s portfolio. References to asset allocation refer to the amount of the Fund’s assets that the Adviser will apportion to the individual sleeves
of the Fund managed according to the model portfolios provided by the Subadvisers. The Registrant has revised the disclosure as presented in response to Comment 5 above in response to this
comment.

 March 24, 2023

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 4

COMMENT 7:

(Prospectus)

Please clarify how the Adviser’s “enhanced risk-adjusted investment outcome” is determined, the factors it considers, the metrics that measure it and circumstances in which it would be reset (e.g., if it resets with a
certain frequency).

Response:

The Registrant has incorporated the comment by removing the reference to an “enhanced risk-adjusted investment outcome” and further revising the disclosure as presented in response to Comment 5.

COMMENT 8:

(Prospectus)

As presented, the description of the subadviser model strategies is materially deficient. In both the Item 4 and Item 9 principal strategy sections, identify each of the relevant subadvisers by name, describe their individual
strategies and models, and identify the percentage or percentage range of assets the Adviser intends to allocate to that model. The type of information and level of detail provided in the strategy and risk disclosures should be equivalent to the
corresponding sections in the issuer’s Harbor Disruptive Innovation ETF prospectus. If a subadviser’s strategy or model focuses on companies within a particular industry, sector or geographical region, please tailor the strategy and risk
narrative descriptions accordingly. In your response letter, please confirm the Registrant will delay the filing’s effectiveness until related comments are resolved.

Response:

 The Registrant confirms that it will delay the filing’s effectiveness until all comments related to this comment are resolved. The
Registrant further confirms that the name of each subadviser will be included in the bracketed placeholders currently included in the prospectus. Additionally, the Registrant has revised its Item 4 strategy disclosure by including the following:

 “The Advisor has selected Connacht Asset Management, LP
(“Connacht”), Copeland Capital Management, LLC (“Copeland”), Granahan Investment Management, LLC (“Granahan”), Huber Capital Management, LLC (“Huber”) and Reinhart Partners, Inc. (“Reinhart”) to each
serve as a Subadvisor to the Fund.”

 The Registrant respectfully declines to
state in the registration statement the percentage of assets the Advisor intends to allocate to each model. The Registrant notes that these allocations may change over time depending on various factors, including the performance of the individual
models and general market conditions.

 March 24, 2023

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 5

 The Registrant has added the following Item 9 disclosure describing the Fund’s use of model portfolios and the investment strategies of
each Subadvisor:

 “USE OF MODEL PORTFOLIOS

 The Advisor receives model portfolios from the Subadvisors and constructs a portfolio
based on the Advisor’s allocation to each Subadvisor’s strategy. The Advisor purchases securities for the Fund consistent with the aggregation of the model portfolios, but may deviate from such aggregation under certain circumstances,
including when the recommended securities are not available in the specific quantities or prices sought by the Subadvisor or when purchasing such securities in conjunction with the Fund’s existing holdings would violate an investment
restriction of the Fund.

 The Advisor may determine that the Fund should, at any
given time, have exposure to a variety of principal investment styles, which are intended to complement one another, and selects Subadvisors for the Fund after assessing their strategies alone and in combination with the other Subadvisors selected
for the Fund. Connacht recommends securities to the Advisor based on a fundamentally and conviction-driven investment approach focused on high or improving quality characteristics. Copeland selects companies based on fundamental stock selection
criteria, including companies’ dividend payments. Granahan employs a fundamental, bottom-up process that seeks to identify companies well positioned for growth and monitors companies’ valuation
metrics. Huber seeks long-term total investment return through capital appreciation, recommending companies whose stocks it considers to be undervalued. Reinhart utilizes a bottom-up research process with a
long-term investment focus that seeks to take advantage of market and behavioral

 inefficiencies.”

COMMENT 9:

 (Prospectus)

 Given the small capitalization focus of the Fund, please supplementally represent that the Fund will not invest principally in emerging
market issuers. Otherwise, please add emerging markets disclosure to the principal investment strategy and risks.

Response:

The Registrant confirms that the Fund will not invest principally in emerging market issuers.

COMMENT 10:

(Prospectus)

 If the Fund is advised by or sold through an insured depositary institution, please add, or direct the Staff to, the statement required by
Item 4(b)(1)(iii) of Form N-1A.

Response:

The Registrant confirms that the Fund is not advised by or sold through an insured depositary institution.

 March 24, 2023

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 6

COMMENT 11:

 (Prospectus)

The basis for the “Non-Discretionary Implementation Risk” is unclear. The risk description is too difficult
to understand. Please revise to explain what a non-discretionary subadviser is and how a subadviser’s discretionary or non-discretionary status creates a risk to
investors. Please explain the term, clarify the relationship between the risk and the principal strategy creating it and rewrite the risk in plain English.

Response:

 The Registrant has incorporated this comment by revising the disclosure as follows:

 “Non-Discretionary Implementation Risk:
Because the Fund is managed pursuant to model portfolios provided by non-discretionary Subadvisers that construct the model portfolios but have no authority to effect trades for the Fund’s
portfolio, it is expected that the Advisor will effect trades will be effected on a periodic basis as the Advisor receives the model portfolios and therefore less frequently than would typically
be the case if the Fund employed discretionary subadvisors that effected trades for the Fund’s portfolio directly were employed. Given that values of investments change with market conditions,
a trade may ultimately be less advantageous for the Fund at the time of implementation than it would have been if it were implemented at the time the non-discretionary subadvisor included it in its model
portfolio. thisThis could cause the Fund’s return to be lower than if the Fund employed discretionary subadvisors.”

COMMENT 12:

 (Prospectus)

Please supplementally explain why “Issuer Risk” is listed as a principal risk of the Fund. We note that nothing in the strategy description suggests
the Fund’s assets will be heavily invested in a particular issuer or a small group of issuers. This is also a diversified fund. Please delete or include disclosure describing the strategic basis for the risk.

Response:

The Registrant feels that the inclusion of “Issuer Risk” as a principal risk of the Fund is appropriate as the Fund can be impacted by events affecting individual issuers, even if it does not invest heavily in a particular
issuer or small group of issuers. The Registrant therefore respectfully declines to make any changes in response to this comment.

 March 24, 2023

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 7

COMMENT 13:

 (Prospectus)

Please revise the “Selection Risk” disclosure to identify the main Fund performance vulnerability more explicitly. As written, it is not clear
whether “Selection Risk” is a subadvisory judgment issue or a consequence of managing a multi-subadviser strategy. Please rewrite the second sentence to illustrate whether the underperformance of model constituents is the result of
(i) the subadviser’s poor model creation/design decisions or (ii) the operational constraints on how the Adviser implements the model recommendations. Consider whether some of the operational challenges would be more appropriately
addressed in the Multi-Manager Risk description.

Response:

 The Registrant believes that both factors referenced above contribute to the Fund’s selection risk. The subadviser’s model
creation/design decisions may lead to poor performance. Furthermore, the Adviser may be constrained in its ability to implement model portfolio recommendations at the time they would be most advantageous for the Fund. The Registrant has revised the
disclosure as follows to improve clarity.

 “Selection Risk: The
Subadvisors’ judgment about the attractiveness, value and growth potential of a particular security may be incorrect, which may cause the Fund to underperform. Additionally, Thethe Advisor
potentially will be prevented from executing investment decisionsimplementing model portfolio recommendations at an advantageous time or price as a result of domestic or global market disruptions, particularly
disruptions causing heightened market volatility and reduced market liquidity, as well as increased or changing regulations. Thus, investments that the Adviser believes represent an attractive opportunity or in which the Fund seeks to obtain
exposure may be unavailable ent