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June 13, 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.
Amendment No. 3 to Registration Statement on Form F-1
Filed June 3, 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 January 30, 2024, letter.
Amendment No. 3 to Form F-1
General
1.We note your revisions in response to our prior comment 3. In some instances, it appears
these revisions removed updates and reinstated earlier disclosure which does not reflect
legislative and other developments that have occurred to date. Accordingly, please further
revise your disclosure to reflect appropriate updates, including the following items:

•Your discussion of the Holding Foreign Companies Accountable Act should reflect
the amendments of the Consolidated Appropriations Act, 2023, and related
regulations. Include that trading in your securities may be prohibited under the
Holding Foreign Companies Accountable Act, as amended by the Consolidated

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 June 13, 2024 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
June 13, 2024
Page 2
Appropriations Act, 2023, and related regulations if the PCAOB determines that it
cannot inspect or investigate completely your auditor for a period of two consecutive
years, and that as a result an exchange may determine to delist your securities.

•Revise disclosure that refers to past events in the future tense (for example, and
without limitation, "The SEC will begin to identify and list Commission-Identified
Issuers on its website shortly after registrants begin filing their annual reports for
2021" and "The PCAOB . . . is making plans to resume regular inspections in early
2023").

•Revise disclosure indicating that approval of the CSRC or other PRC authorities is
not required (for example, on pages 15, 29, and 32) for consistency with disclosure
elsewhere indicating that you have applied for and received CSRC approval in
connection with your listing.

•Update disclosure on page 64 regarding cash transfers between the holding company
and its subsidiaries to additionally refer to the year ended December 31, 2023.
2.We note disclosure that your PRC subsidiaries have obtained "substantially all"
permissions and approvals required for your operations. Please revise your disclosure to
describe each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business. State affirmatively whether you have
received all requisite permissions or approvals and whether any permissions or approvals
have been denied. Please also describe the consequences to you and your investors if you
or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and you are required to obtain such
permissions or approvals in the future. Without limitation, your disclosure should
specifically address the approval of the Ministry of Commerce related to the
reorganization that was completed on January 14, 2022, which is referenced on page 92.
Signatures, page II-6
3.Please revise to identify the individual(s) signing in the capacities of your principal
financial officer and accounting officer or controller. Please also note that the registration
statement should be signed by the majority of your board of directors. Refer to the
Instructions to Signatures on Form F-1.
Exhibits
4.We note that your Management section identifies several director nominees. Please file
consents for the director nominees as exhibits to your registration statement. Refer to Rule
438 of Regulation C.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 June 13, 2024 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
June 13, 2024
Page 3
            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 Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh