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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

EDWIN BATISTA

edwin.batista@dechert.com

 +1 617 728 7165 Direct

 February 21, 2025

 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. 70

File Nos. 333-255884; 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. Kimberly Browning of the Division of Investment
Management with respect to Post-Effective Amendment (“PEA”) No. 70 to the Registrant’s registration statement on Form N-1A under the Securities Act of 1933, as amended (the “1933
Act”). PEA No. 70 was filed in connection with certain changes being made to Harbor Multi-Asset 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. 70.

COMMENT 1:

To the extent the filing contains blank or bracketed information, please confirm the Registrant will file a complete registration statement in its next amendment.

Response:

The Registrant confirms that it will file a complete registration statement in its next amendment.

COMMENT 2:

Please provide responses as soon as possible but at least within five business days prior to the date of effectiveness.

Response:

The Registrant acknowledges this comment and has responded accordingly.

COMMENT 3:

Comments are global and apply to identical or similar pieces of disclosure in the filing.

Response:

The Registrant acknowledges this comment and has responded accordingly.

 February 21, 2025

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 2

COMMENT 4:

If you determine to decline a comment, please explain your position including your well-reasoned legal arguments in support of your views.

Response:

The Registrant acknowledges this comment and has responded accordingly.

COMMENT 5:

Please do not rephrase comments to state they are for consideration unless the Staff explicitly says the comments are for consideration.

Response:

The Registrant acknowledges this comment and confirms that it has not rephrased the Staff’s comments.

COMMENT 6:

The reference to the Commodities and Futures Trading Commission (“CFTC”) has been deleted from the statement required by Rule 481 under the 1933 Act. Please add this reference back or supplementally explain your basis
for removing.

Response:

The Registrant notes that revisions to the Fund’s disclosures in response to the Staff’s comments will be filed in conjunction with the annual update to the Registrant’s registration statement pursuant to Rule
485(b) under the 1933 Act. The Registrant confirms that the Registrant’s registration statement will contain the reference to the CFTC in the statement required by Rule 481 under the 1933 Act.

COMMENT 7:

The Staff notes that the Item 4 risk disclosure includes disclosure regarding the risks of investing in small capitalization companies. The principal investment strategy does not describe the capitalizations of the Fund’s
applicable investments. Such disclosure should be added to the Item 4 investment strategy section and attendant Item 4 risk disclosure should be added as well.

Response:

 The Registrant has incorporated this comment and revised the disclosure as set forth in response to Comment 12 to indicate that the Fund
may invest in issuers of all market capitalizations. Furthermore, the Registrant has deleted the Item 4 risk disclosure regarding small cap issuers and added the following Item 4 risk disclosure:

 “Market Capitalization Risk: The Fund may invest in companies of
any market capitalization. Securities of smaller companies are usually less stable in price and less liquid than those of larger, more established companies. Smaller companies may have limited product lines, markets and financial
resources. Additionally, small- and mid-cap stocks may fall out of favor relative to large cap stocks, which may cause the Fund to underperform other equity funds that focus on larger
capitalized companies. Likewise, large cap stocks may fall out of favor relative to small- and mid-cap stocks, which may cause the Fund to underperform other equity funds that focus on smaller
capitalized companies.”

 February 21, 2025

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 3

COMMENT 8:

To the extent the Fund invests in REITs directly or indirectly through Underlying Funds, please describe the specific types of REITs in which the Fund will invest as part of its principal investment strategy and the attendant
risks.

Response:

While the Registrant may obtain exposure to REITs through investments in Underlying Funds, the Fund’s current exposure to REITs is negligible. The Registrant therefore does not believe that further disclosure regarding REITs
is necessary. The Registrant confirms that if the Fund’s exposure to REITs materially increases, it will consider revising the Fund’s principal investment strategy to add specificity regarding these investments.

COMMENT 9:

Please describe the specific types of commodities in which the Fund will invest as part of its principal investment strategy and the attendant risks. This includes investments made by the Subsidiary.

Response:

 The Registrant has revised the disclosure to indicate that the Fund’s commodity exposure is primarily an exposure to gold as set
forth below in response to comment 12. Furthermore, the Registrant has added the following Item 4 risk disclosure regarding precious metals:

“Precious Metals Investment Risk: Prices of precious metals, including gold and silver, and of precious metal-related financial instruments
historically have been very volatile and may fluctuate sharply over short periods of time. The high volatility of precious metals prices may adversely affect the prices of financial instruments that derive their value from the price of underlying
precious metals. The production and sale of precious metals by governments or central banks or other larger holders can be affected by various economic, financial, social and political factors, which may be unpredictable and may have a significant
impact on the prices of precious metals.”

COMMENT 10:

The Fund’s principal investment strategy says it may invest in cash and cash-equivalents. Please specify the types of cash-equivalents in which the Fund will invest as part of its principal investment strategy and the
attendant risks.

Response:

The Fund does not invest in cash-equivalents as part of its principal investment strategy and the Registrant has deleted the reference to cash-equivalents from the Fund’s principal investment strategy disclosure as shown in
the response to Comment 12.

COMMENT 11:

Any management fees paid by the Subsidiary should be reflected in the Management Fee line item in the expense table. Other expenses related to the Subsidiary should be reflected in the Other Expenses line item in the expense
table. Please revise the footnote to the expense table to state in plain English what expenses are incurred by the Fund through the Subsidiary. If the Subsidiary does not pay a management fee, please clarify that is the case and, accordingly, no
such fees are reflected in the fee table.

Response:

The Fund’s investment advisory agreement reflects a unitary fee structure whereby the Advisor will bear the operating expenses of the Fund, with certain exceptions. This includes the expenses associated with investment in
the Subsidiary (subject to exceptions for certain types of expenses, which exceptions apply at both the Fund and Subsidiary level). Accordingly, the Fund is not bearing any incremental expenses related to establishing the Subsidiary. The Registrant
therefore believes that it is not necessary to further revise the disclosure.

 February 21, 2025

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 4

COMMENT 12:

The disclosure states that the Fund “generally invests through underlying Funds, but it may also invest directly” in certain investments. The disclosure elsewhere states that the Fund pursues its investment objective
“primarily through investments in a diversified portfolio of” Underlying Funds. Please reconcile the use of the terms “generally” and “primarily” with respect to the Fund’s investments in Underlying Funds. In
particular, please delete “generally” or explain why it is not misleading.

Response:

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

 “To seek to achieve the Fund’s investment objective, Harbor
Capital Advisors Inc., the Fund’s investment adviser (the ‘Advisor’), allocates the Fund’s assets among various asset classes and market sectors based on its assessment of global economic and market
conditions, primarily through investments in a diversified portfolio of exchange-traded funds, including other funds managed by the Advisor (‘Underlying Funds’).

 The Fund invests in Underlying Funds that provide exposure to one or more broad
asset classes that include, such as equities (including securities of all capitalizations), fixed income securities of any credit quality (including below-investment
grade bonds, also known as high-yield bonds or ‘junk’ bonds), real estate investment trusts, commodities (primarily gold), U.S. government securities and cash and cash
equivalents. The Fund invests, through Underlying Funds, in markets around the world, including both in developed and emerging markets. The Fund generally invests in Underlying Funds that seek to track indices, including
those designed to provide exposure to particular sectors or industries (such as communication services, financials and/or technology) or style factors (such as growth, value, and/or low volatility). However, the Fund may invest in
Underlying Funds that are actively managed. While the Fund primarilygenerally invests through Underlying Funds, it may also invest directly in fixed income securities and derivatives, such
as futures and options, in limited circumstances where the Advisor believes that a particular exposure is better achieved through direct investments. The Fund’s indirect and direct investments may be in
the securities of foreign and emerging market issuers, which may be denominated in currencies other than the U.S. dollar.”

COMMENT 13:

Please specify the types of equity and fixed-income securities, as well as the specific types of derivatives, in which the Fund invests as part of its principal investment strategy along with their attendant risks.

Response:

The Registrant respectfully notes that the Fund can obtain exposure to a wide variety of investments indirectly through the Underlying Funds and the Registrant believes that the current strategy and risk disclosure is
appropriate.

 February 21, 2025

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 5

COMMENT 14:

Please disclose in the Item 4 disclosure the specific purposes for which the Fund will invest in derivatives as part of its principal investment strategy.

Response:

The existing disclosure regarding the Fund’s principal investment strategy states that the Fund may invest in derivatives when the Advisor determines that a particular exposure is best achieved through such investments.
Furthermore, the Fund’s principal investment strategy disclosure regarding the Subsidiary indicates that the Subsidiary may invest in derivatives to facilitate the Fund’s intended commodity exposure. The Registrant believes that the
disclosure regarding the purposes for the Fund’s investments in derivatives is appropriate.

COMMENT 15:

The Item 4 strategy disclosure describes the Fund’s principal investment strategy in general terms. Please revise generally to add specificity.

Response:

The Registrant notes that it has revised the description of the Fund’s principal investment strategy in response to the Staff’s comments set forth in this letter. The Registrant respectfully believes that no other changes
are required to satisfy the requirements of Form N-1A.

COMMENT 16:

The Fund is required to specify how the Fund intends to achieve its investment objective by describing the investments it will make. Accordingly, please delete terms suggesting that the Fund’s investment strategy is incomplete.
For example, please delete the phrase “such as” when listing investments in which the Fund will invest.

Response:

The Registrant has incorporated this comment and revised the disclosure as set forth in the response to Comment 12.

COMMENT 17:

Please disclose that the Fund complies with the provisions of the Investment Company Act governing investment policies on an aggregate basis with the Subsidiary. Please disclose that the Fund complies with the provisions of the
Investment Company Act governing capital structure and leverage on an aggregate basis with the Subsidiary, such that the Fund treats the Subsidiary’s debt as its own. Please disclose that the Subsidiary complies with provisions regarding
affiliated transactions and custody. Disclose the identity of the Subsidiary’s custodian, if applicable.

Response:

The Registrant respectfully notes that the requested disclosure is included in the subsection of the Fund’s prospectus titled “Investments in the Wholly Owned Subsidiary” under the section “Additional Information
about the Fund’s Investments.” The Registrant further confirms that the Registrant’s registration statement will include the same disclosure that has been made applicable to the Fund and the Subsidiary in its annual update
filing.

 February 21, 2025

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 6

COMMENT 18:

The disclosure states that the Subsidiary has the same “general” investment policies and restrictions. Please delete the term “general.” Please further note that the Fund’s strategy and risk disclosure
should reflect investments and risks relevant through its investment in the Subsidiary.

Response:

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

 “In order to facilitate the Fund’s exposure to commodities, the Fund will
invest up to 25% of its total assets, as determined at the end of each fiscal quarter, in a wholly owned and controlled subsidiary (the “Subsidiary”) organized under the laws of the Cayman Islands. The Fund’s investment
in the Subsidiary is expected to provide the Fund with exposure to commodity returns within the limits of the federal tax laws, which limit the ability of investment companies such as the Fund to invest directly in such
instruments. The Subsidiary has the same investment objective and will follow the same general investment policies and restrictions as the Fund, with the exception
that. Unlike the Fund, the Subsidiary may invest without limitation in exchange-traded products backed by or linked to a physical commodity or commodity-linked derivative
instruments. The Subsidiary’s investment in derivative instruments, including excess return swaps and futures, may have a leveraging effect on the Fund because of the leverage inherent in the use of
derivatives. ReferencesExcept as noted, references to the Fund’s investment strategies and risks include those of its Subsidiary. The Subsidiary is advised by the Advisor.”

COMMENT 19:

Please supplementally confirm that the Subsidiary and its Board of Directors will agree to inspection by the Staff of its books and records, which will be maintained pursuant to Section 31 of the Investment Company Act and the
rules thereunder.

Response:

The Registrant confirms that the Subsidiary and its Board of Directors will agree to inspection by the Staff of its books and records and that such books and records will be maintained pursuant to Section 31 of the Investment
Company Act and the rules thereunder.

COMMENT 20:

Please supplementally confirm that the Subsidiary and its Board of Directors will designate an agent for service of process in the Un