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CORRESP
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CORRESP

 One International Place, 40th Floor

 100 Oliver
Street

 Boston, MA 02110-2605

 +1 617 728 7100 Main

+1 617 426 6567 Fax

 www.dechert.com

 STEPHANIE CAPISTRON

Stephanie.Capistron@dechert.com

 +1 617 728 7127 Direct

+1 617 275 8364 Fax

 June 24, 2024

 VIA
ELECTRONIC TRANSMISSION

 U.S. Securities and Exchange Commission

100 F Street, NE

 Washington, DC 20549

Re:
 Harbor ETF Trust (the “Registrant”)

Post-Effective Amendment No. 47

File Nos. 333-255884; 811-23661

 Ladies and
Gentlemen:

 This correspondence is being filed for the purpose of responding to supplemental comments of the staff of the Securities and
Exchange Commission (the “Staff”) provided by Ms. Rebecca Marquigny of the Division of Investment Management with respect to Post-Effective Amendment (“PEA”) No. 47 to the Registrant’s registration statement on
Form N-1A. We submitted a response letter on the Registrant’s behalf on June 18, 2024 responding to the Staff’s initial comments on PEA No. 47 (the “Prior Letter”).

PEA No. 47 was filed for the purpose of registering shares of Harbor AlphaEdge Small Cap Earners ETF (the “Fund”), a new series
of the Registrant. Note that the Fund was previously named “Harbor Small Cap Earners ETF” but has been renamed “Harbor AlphaEdge Small Cap Earners ETF.”

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. 47.

COMMENT 1:

 (Principal Investment Strategy and Principal Risks – Concentration Risk)

 The Staff reissues Comments 11 and 20 from the Prior Letter relating to the Fund’s
concentration policy. Given that the Index Provider is an affiliate of the Fund, the Staff believes that the Fund cannot rely on the First Australia Fund No Action Letter (July 29, 1999) to concentrate in the manner disclosed and that the
Fund’s concentration policy provides an impermissible level of freedom of action.

 June 24, 2024

 Page 2

Response:

For the reasons set forth in the Prior Letter, the Registrant believes that the Fund’s concentration policy is appropriate and does not provide an impermissible level of freedom of action given the separation between the
investment adviser’s portfolio management and index functions. The Registrant acknowledges that the SEC Staff disagrees.

While the Registrant respectfully declines to change its concentration policy, the Registrant has made the following changes to the Fund’s disclosure to emphasize the lack of freedom to concentrate:

“The Fund will concentrate its investments in a particular industry or group of industries from time to time to approximately the same extent that
the Index concentrates in an industry or group of industries. The Index and, therefore, the Fund may also from time to time have significant exposure to particular sectorsThe Fund may concentrate its
investments in a particular sector, industry or group of industries from time to time to approximately the same extent that the Index concentrates in a sector, industry or group of industries, or as is otherwise necessary to track the performance of
the Index.”

***

“Concentration Risk: The Fund’s assets may be concentrated in a particular sector, industry or group of industries to the extent the Index is so concentrated.
Concentration of the Fund’s assets in a particular sector, industry or group of industries or
significant investment in a particular sector will subject the Fund to the risk that economic, political or other conditions that have a negative
effect on that sector, industry or group of industries will negatively impact the Fund to a greater extent than if the Fund’s assets were
investedconcentrated in a wider variety of sectors or industries.”

***

 June 24, 2024

  Page
 3

 

“The Advisor uses a representative sampling indexing approach to attempt to approximate, before fees and expenses, the investment performance of the Index. The Fund will invest in a representative sample of securities with an
investment profile, collectively, similar to that of the Index. The securities selected are expected to have, in the aggregate, investment characteristics, fundamental characteristics and liquidity measures similar to those of the Index. The Fund
may or may not hold all of the securities in the Index. There also may be instances in which the Advisor may choose to underweight or overweight a security in the Index, purchase securities not in the Index that the
Advisor believes are appropriate to substitute for certain securities in the Index or utilize various combinations of other available investment techniques in accordance with the Fund’s overall strategy as a passively managed index fund. The
Fund may sell securities that are represented in the Index in anticipation of their removal from the Index or purchase securities not represented in the Index in anticipation of their addition to the Index. The Fund does not take
temporary defensive positions when markets decline or appear overvalued.”

***

“The Fund may also, in order to comply with the tax diversification requirements of the Internal Revenue Code of 1986, as amended (“Internal Revenue Code”), temporarily invest in
securities not included in the Index that are expected to be highly correlated with the securities included in the Index.”

***

“The Index is normally reconstituted and rebalanced twice annually. The Index Provider may carry out additional ad hoc index rebalances or delay or cancel a scheduled reconstitution of the Index or the implementation of certain
rules at its sole discretion (for example, in the event of unusual market conditions or other unforeseen circumstances). In general, the addition or removal of securities will occur on the reconstitution dates, and no changes will be made to the
Index between reconstitution dates.

The personnel of the Advisor who are responsible for the day-to-day portfolio management of the Fund have no discretion over the construction of the
Index. The Advisor has implemented and maintains an information barrier around personnel who have access to information concerning changes and adjustments to the Index.

 June 24, 2024

 Page 4

The Fund is entitled to use the Index pursuant to a licensing arrangement with the Index Provider at no charge to the Fund. The Fund does not pay the Index Provider for the use of the Index.”

***

“The Fund may not . . . invest 25% or more of its total assets in the securities of one or more issuers conducting their principal business activities in the same industry or group of industries (excluding the
U.S. government or any of its agencies or instrumentalities), except that the Fund willmay invest
25% or more of its total assets in the securities of one or more issuers conducting their principal business activities in the same industry or group of
industries to approximately the same extent that its underlying Index concentrates in an industry or group of industries, or as is otherwise necessary to track the performance of the Index . . . .”

 If you have any questions or comments concerning the foregoing, please contact the undersigned at (617) 728-7127.

Sincerely,

 /s/ Stephanie Capistron

Stephanie Capistron

Cc:
 Diana R. Podgorny, Esq.

Meredyth Whitford-Schultz, Esq.

Brett Strickland, Esq.

 Harbor
ETF Trust

 Christopher P. Harvey, Esq.

Dechert LLP