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CORRESP
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CORRESP

 1095 Avenue of the Americas

 New
York, NY 10036-6797

 +1 212 698 3500 Main

 +1 212
698 3599 Fax

 www.dechert.com

 KATHERINE COGHLAN

 katherine.coghlan@dechert.com

+1 212 641 5643 Direct

 +1 212 314 0026
Fax

 September 5, 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. 31

(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 Melissa McDonough on July 5, 2023 and by David
Mathews on July 25, 2023 with respect to Post-Effective Amendment (“PEA”) No. 31 to the Registrant’s registration statement on Form N-1A (the “Registration Statement”). PEA No. 31 was filed in connection with
the registration of shares of a new series of the Registrant, Harbor Long-Short Equity 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. 31.

Accounting Comments Provided by Melissa McDonough on July 5, 2023

 COMMENT 1:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 The Staff notes that the fees and expense tables are open
for completion. The Staff may provide additional comments after reviewing the completed tables.

 Response:

 The Registrant has attached a completed fee table in Appendix A to this letter.

 COMMENT 2:

 (Prospectus—Fund Summary—Performance)

 Please consider whether certain additional disclosures are
required by Rule 6-11 of Regulation S-X given that the fund being acquired (“Predecessor Fund”) is a private fund.

 Response:

 The Registrant has reviewed the requirements of Rule 6-11 of Regulation S-X and confirms that the Predecessor Fund’s
audited financial statements as of December 31, 2022 will be included in the definitive filing. The Registrant will also include the supplemental financial information required by Rule
6-11(d).

 September 5, 2023

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 2

 COMMENT 3:

 (Prospectus—Fund Summary—Performance)

 Please include additional discussion regarding how the
Predecessor Fund and the Fund align, as well as any differences.

 Response:

 The Registrant believes that the current disclosure describes the similarities and differences between the Predecessor Fund
and the Fund in the appropriate level of detail. Accordingly, the Registrant respectfully declines to revise the disclosure in response to this comment.

 Legal Comments Provided by David Mathews on July 25, 2023

 COMMENT 4:

 (Prospectus—Front Cover Page)

 Please provide the Fund’s ticker symbol (either in
correspondence or in the 485(b) filing).

 Response:

 The Registrant confirms it will include the Fund’s ticker symbol in the Fund’s 485(b) filing.

 COMMENT 5:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 Please supplementally provide the completed fee table and
clarify that the footnote to the fee table describing the unitary fee includes a complete list of the expenses not covered by the unitary fee.

 Response:

 The Registrant has attached a completed fee table in Appendix A to this letter. The Registrant confirms that the footnote
to the fee table describing the expenses not covered by the unitary fee includes a complete list of such expenses.

 COMMENT 6:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 In supplemental correspondence, please explain how the
Fund’s “Other Expenses” were estimated and how it was determined that such estimate is reasonable.

 Response:

 Pursuant to Instruction 6(a) to Item 3 of Form N-1A, the Registrant has estimated the “Other Expenses”
it expects the Fund to incur during the fiscal year. In determining its estimated expenses, the Registrant considered the expenses to which the Fund is subject outside of the unitary management fee based on the Fund’s reasonably anticipated
asset level.

 COMMENT 7:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 Please supplementally confirm that the 12b-1 fee reflected
in the fee table will be 0.00% or, if it will not be 0.00%, please confirm that the 12b-1 fee will not exceed 0.25% of the Fund’s average net assets.

 September 5, 2023

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 3

 Response:

 The Registrant confirms that the 12b-1 fee reflected in the fee table will be 0.00%. While the Fund plans to adopt a Rule
12b-1 plan permitting the payment of Rule 12b-1 fees, there is no present intention for the Fund to make such payments.

 COMMENT 8:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 Please confirm in supplemental correspondence if it is
anticipated that the Fund will incur acquired fund fees and expenses greater than 0.01% in its first year of operations. If so, please add a separate line item relating to acquired fund fees and expenses in the fee table.

 Response:

 The Registrant confirms that the Fund is not anticipated to incur acquired fund fees and expenses greater than 0.01% in its
first year of operations.

 COMMENT 9:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 Footnote three to the fee table refers to the
“investment strategy best suited to seek the objective of the Fund.” Please revise this disclosure to clarify that “best suited” refers to the Subadvisor’s or Advisor’s judgment or remove “best
suited.”

 Response:

 The Registrant has incorporated this comment and revised the disclosure as follows:

 2 “‘Other expenses’ are estimated for the current fiscal year. ‘Other Expenses’ consist of interest expense paid on borrowing with respect to long positions, which result
from the Fund’s use of alternative financing transactions, such as reverse repurchase agreements and borrowing on a line of credit. These expenses are not payable by the Advisor under the unitary fee arrangement.”

 3 “DividendsDividend and Interest Expense on Short Sales” reflect interest expense and dividends paid on borrowed securities. Interest
expenses result from the Fund’s use of prime brokerage arrangements to execute short sales. Dividends paid on borrowed securities are an expense of short sales. TheseSuch expenses are
required to be treated as a Fund expense for accounting purposes and are not payable by the Advisor under the unitary fee arrangementto Harbor Capital Advisors, Inc. Any interest expense
amount or dividends paid on securities sold short will vary based on the Fund’s use of those investments as an investment strategy best suited to seek the objective of the
Fund.

 September 5, 2023

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 4

 COMMENT 10:

 (Prospectus—Fund Summary—Fees and Expenses of the Fund)

 Please supplementally confirm whether the Fund’s
portfolio turnover rate is anticipated to be greater than 100% and if so, please revise the disclosure accordingly. The Staff notes that one section of the Prospectus states that the Fund will not engage in frequent trading, but portfolio turnover
rate risk is included as a principal risk of the Fund.

 Response:

 The Registrant confirms that the Fund’s portfolio turnover rate is anticipated to be greater than 100%. The Registrant
has removed the disclosure noted by the Staff stating that the Fund will not engage in frequent trading.

 COMMENT 11:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 The principal investment strategy disclosure states that
the Fund will invest primarily in large cap and mid cap companies and also states that the Fund may invest up to 15% in foreign issuers. Please revise the disclosure to clarify if foreign investments will be in large cap and mid cap companies or if
there is a different capitalization range for foreign securities. Please also revise the disclosure to state whether the Fund’s investment in foreign issuers will be in listed securities or in private, unlisted securities.

 Response:

 The Registrant has incorporated this comment and revised the disclosure as follows:

 “The Fund
may also invest in U.S. Treasury bills and derivatives, including listed and over-the-counter options. The Fund may invest up to 15% of its total assets in the securities of U.S. listed foreign issuers of large cap and mid cap
companies.”

 COMMENT 12:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 Please clarify in supplemental correspondence whether the
Fund’s short selling activity, use of derivatives and reverse repurchase agreements will result in the Fund being a general derivatives user under Rule 18f-4 under the Investment Company Act of 1940, as amended (the “1940 Act”)
(i.e., subject to the program requirements, limit on fund leverage, and board reporting requirements) or if the Fund expects to be a limited derivatives user under the rule.

 Response:

 The Registrant confirms that the Fund will be classified as a general derivatives user under Rule 18f-4.

 COMMENT 13:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 With respect to the third bullet point included in the
principal investment strategy, in order to aid investor understanding of the Fund’s strategy, please clarify that this bullet correlates to the description of the long model provided later in the strategy
disclosure.

 September 5, 2023

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 5

 Response:

 The Registrant has incorporated this comment and revised the disclosure as follows:

 “With
respect to the long model, withinWithin each group, proprietary stock selection factors determined based upon conversations with company management and third-party fundamental
analysts;”

 COMMENT 14:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 Please revise the following disclosure using plain
English: “based on macroeconomic data that forecasts time varying views of risk that the market has historically rewarded.”

 Response:

 The Registrant has incorporated this comment and revised the disclosure as follows:

 “The
Subadvisor’s proprietary macroeconomic regime model designates three regimes - value, neutral, and momentum - based on the Subadvisor’s analysis of macroeconomic data that forecasts time varying views of risk that the
market has historically rewarded, as determined by the Subadvisor is consistent, in the Subadvisor’s view, with market participants’ willingness to accept less, average, or more risk in their portfolios. This
macroeconomic data includes but is not limited to data on banks, employment, housing, industrial production, and securities markets. The Subadvisor uses this macroeconomic data to determine the weights of various stock selection factors and
gross and net exposures for the Fund. In periods when its analysis of macroeconomic data suggests to the Subadvisor that investors may be willing to accept more risk, the Subadvisor will seek to enter a momentum regime, whereas in periods when
the data suggests investors may be willing to accept less risk, the Subadvisor will seek to enter a value regime.”

 COMMENT 15:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 Please revise the disclosure to clarify how the Subadvisor
uses macroeconomic data to determine weights of various stock selection factors.

 Response:

 The Registrant has incorporated this comment and revised the disclosure as presented in response to Comment
14.

 COMMENT 16:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 Please revise the disclosure to clarify that the
Subadvisor’s investment focus on industry group is limited to the Fund’s fundamental policy not to

 September 5, 2023

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 6

 concentrate in a particular industry. In addition, please clarify in disclosure how the Subadvisor forms its views with
respect to industry focus.

 Response:

 The Registrant has incorporated this comment and revised the disclosure as follows:

 “Industry
Group Focus. It is the Subadvisor’s view, that the opportunity for positive returns for active management are not equal among industry groups. For this reason, the Subadvisor will focus on those industry groups that, in
its view, have the greatest potential to add value through the stock selection process over time by starting with the Index and further narrowing that universe by focusing on industry groups exhibiting the highest dispersion in
returns over time. The Subadvisor’s investment focus on industry group is limited by the Fund’s fundamental policy not to concentrate in a particular industry.”

 COMMENT 17:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 The Staff notes that the sub-sections of the principal
investment strategy disclosure describing the long model and short model both reference US large cap companies but earlier sections of the strategy reference US large cap and mid cap companies as well as foreign investments. Please clarify in the
disclosure if the long model and short model only include large cap issuers or if mid cap companies and foreign issuers are also included in the long and/or short models.

 Response:

 The Registrant notes that the long model and the short model apply to all equity securities in which the Fund invests. The
Registrant has revised the disclosure as follows:

“Long Model. In investing in long positions in equity securities of U.S. large cap
companies, the Subadvisor utilizes a multifactor model to identify the stocks that are likely to deliver the best upside returns. These factors fall into the broad groups of valuation, quality, profitability, and momentum, and are
determined based on the Subadvisor’s experience and conversations with company management and third-party fundamental analysts and are specific to each industry group. The Subadvisor will vary the weights to the factor groups
depending on the regime in place at the time, as determined by the Subadvisor (for example, the value factor weights having greater emphasis in value regimes).

Short Model. The Subadvisor will identify equity securities of U.S. large cap
companies that it believes will underperform using a separate short model that analyzes several factors, such as value, quality, profitability, and momentum that the Subadvisor believes will be more effective for
this

 September 5, 2023

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 7

 purpose. These factors seek to increase the spread of the performance
between the long side of the strategy and the short side of the strategy to better capture the downside returns. The Subadvisor will sell these stocks short on behalf of the Fund. When the Fund shorts securities of a company, it borrows
shares of that company which it then sells. The Fund closes out a short sale by purchasing the security that it has sold short and returning that security to the entity that lent the security. Short sales are considered speculative transactions and
a form of leverage.”

 COMMENT 18:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 With respect to the disclosure describing the short model,
the first sentence states that the Subadvisor analyzes several factors. Please revise the disclosure to clarify what those factors are. In addition, please revise the second sentence in this paragraph using plain English.

 Response:

 The Registrant has incorporated this comment and revised the disclosure as presented in response to Comment
17.

 COMMENT 19:

 (Prospectus—Fund Summary—Principal Investment Strategy)

 Please revise the disclosure to include a discussion
relating to the Advisor’s allocation of the management of the Fund’s assets to the Subadvisor.

 Response:

 The Registrant respectfully notes that Form N-1A does not require such disclosure to be included in the principal
investment strategy section of the Prospectus. Further, the Registrant respectfully notes that the Prospectus includes a discussion of the Advisor and its ability to either manage funds directly or employ a “manager of managers” approach
in response to Item 10 of Form N-1A. Accordingly, the Registrant respectfully declines to make any changes in response