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January 30, 2024
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.
Amended Registration Statement on Form F-1
Filed on January 17, 2024
File No. 333-270958
Dear Yujun Xiao:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our June 8, 2023 letter.
Amendment No. 2 to Form F-1 filed January 17, 2024
Our Properties and Facilities, page 86
1.Please file as an exhibit the lease agreements for all leased properties.
Related Party Transactions, page 103
2.We note your response to prior comment 2. Please file all outstanding loan agreements as
exhibits to your registration statement, including those subsequent to May 31, 2023.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 30, 2024 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
January 30, 2024
Page 2
General
3.We note the changes you made to your disclosure appearing on the cover page, Summary
and Risk Factor sections relating to legal and operational risks associated with operating
in China and PRC regulations.  It is unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on May 31, 2023
warranting revised disclosure to mitigate the challenges you face and related disclosures.
The Sample Letters to China-Based Companies sought specific disclosure relating to the
risk that the PRC government may intervene in or influence your operations at any time,
or may exert control over operations of your business, which could result in a material
change in your operations and/or the value of the securities you are registering for sale.
We remind you that, pursuant to federal securities rules, the term “control” (including the
terms “controlling,” “controlled by,” and “under common control with”) as defined in
Securities Act Rule 405 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.”  The Sample Letters also
sought specific disclosures relating to uncertainties regarding the enforcement of laws and
that the rules and regulations in China can change quickly with little advance notice.  We
do not believe that your revised disclosure referencing the PRC government’s intent to
strengthen its regulatory oversight conveys the same risk.  Please restore your disclosures
in these areas to the disclosures as they existed in the registration statement as of May 31,
2023.
            Please 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