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December 16, 2022
Zhengjun Tao
Chief Executive Officer
Haoxin Holdings Limited
Room 329-1, 329-2, No.1 Xingye Yi Road
Ningbo Free Trade Zone
Ningbo, Zhejiang Province 315807
People's Republic of China
Re:Haoxin Holdings Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted December 5, 2022
CIK No. 0001936817
Dear Zhengjun Tao:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 6, 2022 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1, submitted December 5, 2022
Cover Page
1.We note your disclosure that your former auditor, Friedman LLP, and current
auditor, Marcum Asia CPAs LLP, are not subject to the determinations announced by the
PCAOB on December 16, 2021. However, we also note your disclosure that the company
is subject to regulations under the HFCAA. Please revise this statement to clarify whether
the Holding Foreign Companies Accountable Act and related regulations currently affect
the company.

 FirstName LastNameZhengjun Tao
 Comapany NameHaoxin Holdings Limited
 December 16, 2022 Page 2
 FirstName LastName
Zhengjun Tao
Haoxin Holdings Limited
December 16, 2022
Page 2
Prospectus Summary, page 1
2.We note your response to prior comment 3, and reissue such comment in part. We note
your definition of "China” or the “PRC,” referring to the People’s Republic of China,
excludes Taiwan and the special administrative regions of Hong Kong and Macau. Please
revise your disclosure throughout your filing to clarify that the legal and operational risks
associated with operating in China also apply to your operations in Hong Kong, including
a clear statement in this section and in your risk factors disclosure that the legal and
operational risks associated with operating in China also apply to your operations in Hong
Kong. In addition, clarify that the PRC government has significant authority to intervene
or influence your Hong Kong subsidiary at any time, which could result in a material
adverse change to your business, prospects, financial condition, and results of operations,
and the value of your securities. In this regard, please ensure that your disclosure does not
narrow risks related to operating in the PRC to mainland China only.
3.We note your disclosure that your customers have been negatively impacted by the
ongoing impact of COVID-19, with revenue generated from your top 10 customers
reduced by $1,516,035 or 21.5%.  Please revise to specify the period during which such
revenue was reduced.
Related Party Transactions, page 143
4.We note your response to prior comment 16, and reissue such comment in part.  With
respect to the amounts due to or from related parties that are described on page 143, please
describe the nature and extent of the underlying transactions.  For example, describe the
nature and extent of the arrangement or agreement that resulted in $82,393 due from
Shenzhen Longanda Environmental Protection Equipment Co., Ltd. as of June 30, 2022.
Please ensure that such information is provided for the period since the beginning of the
company’s preceding three financial years up to the date of the document.  Refer to Item 4
of Form F-1 and Item 7.B.1 of Form 20-F.
Financial Statements
General, page F-1
5.Please advise whether you have published interim financial information covering a more
current period than the six months ended June 30, 2022 that need to be included in your
registration statement pursuant to Item 4(a) of Form F-1 applicable via Form 20-F Item
8.A.5 and Instructions to Item 8.A.5, and whether you are able to represent that you are
not required to comply with the 12-month requirement per Item 8.A.4 and Instructions to
Item 8.A.4.

 FirstName LastNameZhengjun Tao
 Comapany NameHaoxin Holdings Limited
 December 16, 2022 Page 3
 FirstName LastName
Zhengjun Tao
Haoxin Holdings Limited
December 16, 2022
Page 3
Note 6 - Property and Equipment, Net, page F-18
6.We note your response to prior comment 11.  Please add similar disclosures and table to
your Note 6, for both your year end and subsequent interim financial statements,
discussing the different arrangements and accounting treatments for all the vehicles you
own, and showing in the table, as of the end of each period presented, your vehicles and
your equipment balances by categories, also adding to the table a total book value, and
ensuring that such total matches your reported total property and equipment, net balance
as of each corresponding period end.
            You may contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Lily Dang, Staff
Accountant, at 202-551-3867 if you have questions regarding comments on the financial
statements and related matters. Please contact Liz Packebusch, Staff Attorney, at 202-551-8749
or Laura Nicholson, Special Counsel, at 202-551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       William S. Rosenstadt