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ZJK INDUSTRIAL CO., LTD.

January 18, 2024

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: ZJK Industrial Co., Ltd.

  Draft Registration Statement on Form F-1

  Filed September 26, 2023

  File No. 377-06892

Dear Ms. Sidwell:

This letter is in response
to the letter dated October 23, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. The amendment
to Draft Registration Statement on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Draft Registration Statement on Form F-1

General

 1. Please note the financial statement updating requirements as set forth in Item 8.A.5 of the Form
20-F. In this regard, the next submission should also include unaudited interim financial statements and related financial information
for the six months ended June 30, 2023 and 2022.

Response:
Pursuant to the comment, we have included the unaudited interim financial statements and related financial information for
the six months ended June 30, 2023 and 2022  in the Registration Statement.

 2. Please supplementary provide us with copies of all written communications, as defined in Rule 405
under the Securities Act, that you, or anyone authorized to do so on your behalf present to potential investors in reliance on
Section 5(d) of the Securities Act, whether or not they retain copies of the communication.

Response:
Neither the Company nor anyone authorized by the Company has presented any written communications, as
defined in Rule 405 under the Securities Act, to potential investors in reliance on Section 5(d) of the Securities Act. To the
extent that any such written communications are later presented to potential investors, the Company will supplementally provide
copies to the Staff.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 2 of 13

 3. Please disclose whether and how your business segments, products, lines of service, projects, or
operations are materially impacted by supply chain disruptions, especially in light of in light of the effectiveness of the Uyghur
Forced Labor Protection Act (the “UFLPA”). For example, discuss whether you have or expect to:

 · suspend the production, purchase, sale or maintenance of certain items due to a lack of raw materials,
parts, or equipment; inventory shortages; closed factories or stores; reduced headcount; or delayed projects;

 · experience labor shortages that impact your business;

 · experience cybersecurity attacks in your supply chain;

 · experience higher costs due to constrained capacity or increased commodity prices or challenges
sourcing materials (e.g. steel, lithium, nickel, manganese, beryllium, copper, gold or other raw material sourced from Western
China);

 · experience surges or declines in consumer demand for which you are unable to adequately adjust
your supply;

 · be unable to supply products at competitive prices or at all due to export restrictions, sanctions,
tariffs, trade barriers, or political or trade tensions among countries; or

 · be exposed to supply chain risk in light of the effectiveness of the UFLPA and/or related geopolitical
tension.

  Explain whether and how you have undertaken efforts to mitigate the impact and where possible quantify
the impact to your business.

Response: Pursuant to the comment,
we have revised the disclosure on page 37 of the Registration Statement.

Cover Page

 4. Please disclose prominently on the prospectus cover page that you are not a Chinese operating company
but a Cayman Islands holding company with operations conducted by your subsidiaries and through contractual arrangements with a
variable interest entity (VIE) based in China and that this structure involves unique risks to investors. If true, disclose that
these contracts have not been tested in court. Explain whether the VIE structure is used to provide investors with exposure to
foreign investment in China-based companies where Chinese law prohibits direct foreign investment in the operating companies, and
disclose that investors may never hold equity interests in the Chinese operating company. Your disclosure should acknowledge that
Chinese regulatory authorities could disallow this structure, which would likely result in a material change in your operations
and/or a material change in the value of the securities you are registering for sale, including that it could cause the value of
such securities to significantly decline or become worthless. Provide a cross-reference to your detailed discussion of risks facing
the company and the offering as a result of this structure.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 3 of 13

Response: The Company respectfully
advises the Staff that we do not have a VIE structure, and we have revised the disclosure on the cover page of the Registration
Statement to include such statement.

 5. Provide a description of how cash is transferred through your organization and disclose your intentions
to distribute earnings or settle amounts owed under the VIE agreements. State whether any transfers, dividends, or distributions
have been made to date between the holding company, its subsidiaries, and consolidated VIEs, or to investors, and quantify the
amounts where applicable.

Response:
Pursuant to the comment, we have included a description of how cash is transferred through our organization and updated
the amounts of dividends and distributions made by us as of the date hereof on page 5 of the Registration
Statement.

The Company respectfully advises the Staff
that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement to include
such statement.

Commonly Used Define Terms, page 10

 6. Please consider expanding the last paragraph on page 11 to also discuss your 1:2 share split that
occurred on June 19, 2023 and how all related share information has been retroactively reflected. In this regard, we note disclosure
on page F-33 that the shares and per share information are presented on a retroactive basis for the periods presented, to reflect
the reorganization completed on March 28, 2023 and share split that occurred on June 19, 2023. This information should also be
included in a more prominent location within the filing.

Response: Pursuant to the comment,
we have revised the relevant disclosures on the cover page and page 11 of the Registration Statement.

Prospectus Summary, page 12

 7. Please clarify in the last sentence of the introductory paragraph on page 12 that the consolidated
financial statements included in the prospectus are for the years ended December 31, 2022 and 2021. Your current disclosure states
for the years ended December 31, 2021 and 2020.

Response:
Pursuant to the comment, we have revised the disclosure on page 12 of the Registration Statement.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 4  of 13

 8. We note that the consolidated VIEs constitute a material part of your consolidated financial statements.
Please provide in tabular form a condensed consolidating schedule that disaggregates the operations and depicts the financial position,
cash flows, and results of operations as of the same dates and for the same periods for which audited consolidated financial statements
are required. The schedule should present major line items, such as revenue and cost of goods/services, and subtotals and disaggregated
intercompany amounts, such as separate line items for intercompany receivables and investment in subsidiary. The schedule should
also disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that are the primary beneficiary of
the VIEs, and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor
to evaluate the nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts
associated with intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary, additional
disclosure about such amounts should be included in order to make the information presented not misleading.

Response: The Company respectfully
advises the Staff that it does not have a VIE structure and therefore believes that this comment is not applicable to the Registration
Statement.

 9. Disclose clearly that the company uses a structure that involves a VIE based in China and what
that entails, and provide early in the summary a diagram of the company’s corporate structure, identifying the person or
entity that owns the equity in each depicted entity. Describe all contracts and arrangements through which you claim to have economic
rights and exercise control that results in consolidation of the VIE’s operations and financial results into your financial
statements. Identify clearly the entity in which investors are purchasing their interest and the entity(ies) in which the company’s
operations are conducted. Describe the relevant contractual agreements between the entities and how this type of corporate structure
may affect investors and the value of their investment, including how and why the contractual arrangements may be less effective
than direct ownership and that the company may incur substantial costs to enforce the terms of the arrangements. Disclose the uncertainties
regarding the status of the rights of the Cayman Islands holding company with respect to its contractual arrangements with the
VIE, its founders and owners, and the challenges the company may face enforcing these contractual agreements due to legal uncertainties
and jurisdictional limits.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 5 of 13

 10. It is unclear from your disclosure whether the Cayman Islands holding company controls and receives
the economic benefits of the VIE’s business operations through contractual agreements between the VIE and your Wholly Foreign-Owned
Enterprise (WFOE) and that those agreements are designed to provide your WFOE with the power, rights, and obligations equivalent
in all material respects to those it would possess as the principal equity holder of the VIE. We also note your disclosure that
the Cayman Islands holding company is the primary beneficiary of the VIE. However, neither the investors in the holding company
nor the holding company itself have an equity ownership in, direct foreign investment in, or control of, through such ownership
or investment, the VIE. Accordingly, please refrain from implying that the contractual agreements are equivalent to equity ownership
in the business of the VIE. Any references to control or benefits that accrue to you because of the VIE should be limited to a
clear description of the conditions you have satisfied for consolidation of the VIE under U.S. GAAP. Additionally, your disclosure
should clarify that you are the primary beneficiary of the VIE for accounting purposes. Please also disclose, if true, that the
VIE agreements have not been tested in a court of law.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

Corporate Structure, page 17

 11. Please include a paragraph discussion disclosing that Zhongjinke Shenzhen is a variable interest
entity (“VIE”), and that it along with its related consolidated and unconsolidated entities, is a domestic company
incorporated in mainland China in which you do not have any equity ownership but whose financial results have been consolidated
into your consolidated financial statements based solely on contractual arrangements in accordance with U.S. GAAP. In this regard,
also disclose that as a result of your 100% indirect ownership of Zhongjinke WFOE and the contractual arrangements with the VIE,
you are regarded as the primary beneficiary of the VIE and that you treat the variable interest entity as the consolidated VIE
under U.S. GAAP, which generally refers to an entity in which you do not have any equity interest, but consolidate as you have
a controlling financial interest in that entity.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

 12. Refer to the diagram of your corporate legal structure on pages 18 and 92. Please disclose whom
holds the respective 49% and 51% interest in the PRC entities Zhongjinke Nanjing and PSM-ZJK. Also on page 91 regarding the discussion
of the January 10, 2023 share exchange agreement with Ms. Yingjing Deng, describe the ownership structure between Galaxy Exploration
and Zhongjinke Shenzhen prior to and after this agreement, as it is not clear as to the ownership interest or common control interests
of Ms. Deng in either company before the share exchange agreement with Zhongjinke HK.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 6 of 13

Response: We respectfully advise the Staff that we have revised the disclosures on page
19, page 97 and page 98 of the Registration Statement.

Summary Consolidated Financial and Operating
Data, page 32

 13. We note from the introductory paragraph that you are presenting summary consolidated balance sheet
data as of December 31, 2022 and 2021; however, we are not able to locate this balance sheet information. Please revise accordingly
to present the data.

Response: In
response to the Staff’s comment, we respectfully advise the Staff that we revised the disclosure on page 34.

Risk Factors, page 33

 14. Revise your risk factors to acknowledge that if the PRC government determines that the contractual
arrangements constituting part of the VIE structure do not comply with PRC regulations, or if these regulations change or are interpreted
differently in the future, the securities you are registering may decline in value or become worthless if the determinations, changes,
or interpretations result in your inability to assert contractual control over the assets of your PRC subsidiaries or the VIEs
that conduct all or substantially all of your operations.

Response: The Company respectfully
advises the Staff that we do not have a VIE structure and therefore believes that this comment is not applicable to the Registration
Statement.

 15. Given the significant oversight and discretion of the government of the People’s Republic
of China (PRC) over the operations of your business, please describe any material impact that intervention or control by the PRC
government has or may have on your business or on the value of your securities. We remind you that, pursuant to federal securities
rules, the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) means “the possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.”

Response: The Company