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January 19, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted on January 6, 2023
CIK 1945415
Dear Yujun Xiao:
            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 November 16, 2022 letter.
Draft Registration Statement on Form F-1/A filed January 6, 2023
Cover Page
1.We note your response to prior comment 2. Please disclose how you will refer to the
holding company and each subsidiary when providing the disclosure throughout the
document so that it is clear to investors which entity the disclosure is referencing and
which subsidiaries or entities are conducting the business operations.  Specifically, please
disclose how you will be referring to Wuxi Xinwu District Jianmeng Electromechanical
Technology Co., Limited, HUHU Technology Co., Ltd., and HUHUTECH(HK) Limited.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 19, 2023 Page 2
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
January 19, 2023
Page 2
2.We note your response to prior comment 4. Please clarify whether any dividends or
distributions have been made and if so, quantify the amount. If no dividends or
distributions have been made, please revise your disclosure elsewhere in the filing.
Prospectus Summary, page 1
3.We note your response to prior comment 6. Please file the written agreements with the
customers and suppliers mentioned in this section.  Additionally, please clarify the
contracting parties to these agreements in your current corporate structure.
Business Segments, page 24
4.We reissue prior comment 12. Please clarify whether you have multiple business
segments.
Risk Factor
Nasdaq Approval, page 50
5.We note your response to prior comment 15. Please revise your disclosure to add the
consequences to the offering of having your application denied.
Capitalization , page 54
6.We note your capitalization table footnote (1) continues to refer to "non-accountable
expense allowance".  As such, we re-issue our prior comment number 17 in our letter
dated, November 16, 2022.   The prior comment is provided for your convenience:  "The
footnotes to your capitalization table refer to a "non-accountable expense allowance" as a
deduction to expected offering proceeds. Please tell us and explain in your disclosure, the
nature of this adjustment."
Managements Discussion and Analysis of Financial Condition and Results of Operations
Bank Loans, page 70
7.We note your response to prior comment 25. Please file all the outstanding loan
agreements as exhibits to your registration statement. In the alternative, please explain
why you are not required to do so.
8.We reissue prior comment 26. Please discuss your bank loans as sources of liquidity.
Development Opportunities, page 79
9.We note your response to prior comment 29. Please revise to elaborate on how you
determined that these will bring development opportunities.
Business, page 85
10.We note your response to prior comment 30. We reissue our comment. Please explain
how you determined that this Sales and Marketing disclosure is consistent with the

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 19, 2023 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
January 19, 2023
Page 3
operating expenses discussion on page 65, which states that “[s]elling expenses primarily
consisted of salary and compensation expenses relating to our sales personnel, advertising
expenses, promotional service fees . . ."  Additionally, please explain how you determined
that this Sales and Marketing disclosure is consistent with your discussion on page 62
which states that "HUHU Japan just functions as a sales and customer service center."
Properties and Facilities, page 88
11.We note your response to prior comment 31.  Please attach all lease agreements as
exhibits to your registration statement. In the alternative, please explain why you are not
required to do so.
Regulations, page 97
12.We note your response to prior comment 32. Please clarify whether the referenced
reorganization relates to the reorganization that was completed in January 2022 or the
restructuring that was completed in March 2022 and revise the disclosures in the filing.
Related Party Transactions, page 102
13.We note your response to prior comment 40. Please revise this section to include
transactions of all related parties.
            You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh