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ZJK INDUSTRIAL CO., LTD.

June 20, 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.

    Amended
                                            Draft Registration Statement on Form F-1

    Filed
                                            January 19, 2024

    File
                                            No. 377-06892

Dear Ms. Sidwell:

This letter is in response to the
letter dated February 1, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”). The Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Draft Registration Statement on Form F-1 submitted
on January 19, 2024

General

 1. We note your response to prior comment 15 and reissue. Given the Chinese government’s significant
oversight and discretion over the conduct and operations of your business, please revise to describe any material impact that intervention,
influence, or control by the Chinese government has or may have on your business or on the value of your securities. Highlight separately
the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material change in
your operations and/or the value of your securities. Also, given recent statements by the Chinese government indicating an intent to exert
more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers, acknowledge the
risk that any such action could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless. 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: In response to the
comment, the Registration Statement has been revised at pages 46 and 47.

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    2 of 4

Notice to Foreign Investors, page 163

 2. We note that you have removed the “Notice to Foreign Investors” disclosure.
Please advise on why this disclosure was removed from the registration statement.

Response: The section of “Notice
to Foreign Investors” was removed because the section of “Selling Restrictions” on page 163 includes general disclosures
regarding selling restrictions in any jurisdiction other than in the United States on offers and sales in or from any country or jurisdiction
except in compliance with any applicable rules and regulations of any such country or jurisdiction.

Index to Financial Statements, page F-1

 3. We
                                            note your December 31, 2022 audited financial statements are older than 12 months at the
                                            date of this amended registration statement. Please be advised that since this is an initial
                                            public offering of your ordinary shares, you are required to provide updated annual financial
                                            statements and related disclosures pursuant to Item 8.A.4 of Form 20-F, or if applicable,
                                            you should provide the representations required by Instruction 2 to Item 8.A.4 in an exhibit
                                            to the filing.

Response:
In response to the comment, audited financial statements as of December 31, 2023 are included in the Registration Statement being
filed as of the date hereof.

Note
5. Long-Term Investment, page F-51

 4. We
                                            note your response to prior comment 31 that PSM-ZJK Fasteners (Shenzhen) Co., Ltd. (“PSM-ZJK”)
                                            met the significance test at the 33% level and that you have included unaudited financial
                                            statements of PSM-ZJK for the years ended December 31, 2021 and 2022 at Exhibit 99.5. Pursuant
                                            to the analogous requirements of Rule 3-09(b) of Regulation S-X a full set of audited financial
                                            statements should be filed. In this regard, a full set of audited financial statements should
                                            be provided covering each year in which PSM-ZJK met the significance test at the 20% and
                                            above level, including an auditors report and financial statement footnotes. Please revise
                                            the financial statements at Exhibit 99.5 to comply with the requirements accordingly.

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    3 of 4

Response: In response to the
comment, the financial statements of PSM-ZJK have been revised to comply with the requirements of Rule 3-09(b) of Regulation S-X, and
re-filed as Exhibit 99.5 to the Registration Statement being filed as of the date hereof.

Exhibits

 5. Please file material contracts required by Item 601(b)(10) of Regulation S-K as
exhibits to your registration statement. In this regard, we note references to your lock-up agreements and supply agreements.

Response: In response to the comment, the Company respectfully advises the Staff that
we have filed the supply agreements and other material contracts as exhibits to the Registration Statement. We have noted in the exhibit
table that certain exhibits will be filed via amendment to the Registration Statement.

We appreciate the assistance the
Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    4 of 4

    By:
    /s/Kai Huang

    Kai Huang

    Chief Financial Officer

cc:
Jinhua (Anna) Wang, Esq.

Robinson & Cole LLP

[signature page to the SEC response letter]