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January 25, 2023
Edwin Chun Yin Wong
Chief Executive Officer
J-Long Group Ltd
Flat F, 8/F, Houston Industrial Building
32-40 Wang Lung Street, Tsuen Wan
New Territories, Hong Kong
Re:J-Long Group Ltd
Draft Registration Statement on Form F-1
Submitted December 30, 2022
CIK No. 0001948436
Dear Edwin Chun Yin Wong:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
Prospectus Cover Page, page i
1.We note your disclosure that you "intend to apply to list [your] Ordinary Shares on the
Nasdaq Capital Market under the symbol “JL.”  There is no assurance that such
application will be approved, and if [your] application is not approved, this offering may
not be completed."  Please revise to disclose more clearly whether this offering is
contingent upon the final approval of your Nasdaq Capital Market listing.
2.We note your disclosure that you will be a controlled company following the offering.
Please revise to identify the "Controlling Shareholder" and disclose, if true, that the

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 January 25, 2023 Page 2
 FirstName LastNameEdwin Chun Yin Wong
J-Long Group Ltd
January 25, 2023
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Controlling Shareholder will have the ability to determine all matters requiring approval
by stockholders.
3.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash or assets in the business is in Hong Kong or a
Hong Kong entity, the funds or assets may not be available to fund operations or for other
use outside of the Hong Kong due to interventions in or the imposition of restrictions and
limitations on the ability of you or your subsidiaries by the PRC government to transfer
cash or assets. On the cover page, provide cross-references to these other discussions.
4.We note that you do not appear to have relied upon an opinion of counsel with respect to
your conclusions that you do not need any permissions and approvals to operate your
business and to offer securities to investors. If true, state as much and explain why such an
opinion was not obtained.  In addition, please augment your disclosure to discuss how
how came to the conclusion that no permissions and approvals to operate your business
and to offer securities to investors are required, and the basis on which you made that
determination. Please also revise the Permission Required from Hong Kong and PRC
Authorities section on page 12 accordingly.
Recent PCAOB Developments, page 12
5.Please revise this section to reflect the most recent legislative developments regarding the
HFCAA.  In this regard, we note the number of consecutive years an issuer can be
identified as a commission-identified issuer before the Commission must impose an initial
trading prohibition on the issuer’s securities has been reduced from three years to two
years.  Please revise the prospectus throughout as applicable.
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
60
6.Please describe, and quantify to the extent possible, any known trends and uncertainties
that have had or that you reasonably expect will have a material favorable or unfavorable
impact on your revenue or results of operations, in light of the impact of COVID-19 on
your business. Please refer to CF Disclosure Guidance: Topic No. 9.
7.We note your disclosure on page 72, "[a]s we do not own or operate any manufacturing
operations, for products that require conversion, we delegate the converting process of our
products to our manufacturing services suppliers located in the PRC, ..."  With a view
towards disclosure, please tell us whether you have experienced supply chain disruptions.
If applicable, please discuss here whether supply chain disruptions materially affect your
outlook or business goals, specify whether these challenges have materially impacted your
results of operations or capital resources, and quantify, to the extent possible, how your
sales, profits, and/or liquidity have been impacted.  If you have taken actions to lessen the
impact of supply chain issues, if material, quantify the impact of such actions, describe
such actions in greater detail, and discuss known trends or uncertainties resulting from
such actions.

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 January 25, 2023 Page 3
 FirstName LastName
Edwin Chun Yin Wong
J-Long Group Ltd
January 25, 2023
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8.Please revise to disclose your critical accounting estimates.  Refer to Item 5.E. of Form
20-F.
Results of Operations
Revenues, page 62
9.You attribute the increase of total revenue to the increase in revenue from your heat
transfer products and woven labels and tapes products.  Please revise to provide more
robust disclosures regarding the reasons for your revenue increase.  In doing so,
describe the underlying reasons for these material changes in quantitative and qualitative
terms, including the extent to which such changes are attributable to changes in prices or
to changes in the volume or amount of goods or services being sold or to the introduction
of any new products or services.
Cost of Sales, page 62
10.You disclose that the increase in cost of sales was in line with the increase in sales
while the gross profit margin increased to 23.1% from 20.6%.  Please revise to clarify
what appears to be a contradiction and expand your discussion of cost of sales to quantify
and further explain the underlying factors to which changes are attributed.  See Item 5.A.
of Form 20-F and SEC Release No. 33-8350 for guidance.
Liquidity and Capital Resources
Cash Flow
Operating Activities, page 63
11.Please note that your analysis of operating cash flows should focus on factors that directly
affect cash, and not merely refer to results of operations prepared on an accrual basis,
noncash items that do not affect cash, and items reported in the statement of cash flows or
changes in line items presented in your balance sheet without discussing how such items
directly affect cash.  Refer to Section IV.B.1 of SEC Release No. 33-8350 for guidance.
Please revise your disclosure accordingly.
Quantitative and Qualitative Disclosures About Market Risk, page 68
12.Your disclosures with respect to your exposure to currency risk and interest rate risk do
not comply with the guidance in Item 11.(a)(1) of Form 20-F.  Please revise to provide
quantitative disclosures regarding your exposure to currency risk and interest rate risk in
one of the suggested formats outlined in Item 11.(a)(1) of Form 20-F.

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 January 25, 2023 Page 4
 FirstName LastName
Edwin Chun Yin Wong
J-Long Group Ltd
January 25, 2023
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Consolidated Balance Sheets, page F-3
13.Please revise to separately present accounts receivables from and accounts payables to
related parties on your balance sheets and statements of cash flows.  Refer to Rule 4-
08(k), Rule 5-02.3(a), and Rule 5-02.19(a) of Regulation S-X.
Consolidated Statements of Operations and Comprehensive Income (Loss), page F-4
14.Based on the nature and the geographical areas of your operations and your disclosure on
page F-10, it appears that you would have exposure to foreign currency translation.
However, there is no foreign currency translation line item in your statement of
comprehensive income.  Please explain, or revise as necessary.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-15
15.Your disclosure on page F-25 indicates that you have customer deposit received balances
of $449,772 and $269,263 as of March 31, 2021 and 2022.  Please revise to include all
required disclosures in accordance with ASC 606-10-50-8.
16.On page 60 of MD&A, you disclose your revenues from eight types of products for each
of the periods presented in your statement of operations, while in Note 2 to your financial
statements, you break-out your revenues only by heat transfer and non-heat transfer
products.  Please revise the notes to your financial statements to disclose disaggregated
revenues by the categories disclosed on page 60 of MD&A or explain why you do not
believe this is required.  Refer to the guidance in ASC 606-10-60-5 and ASC 280-10-50-
40.
13. Income Tax, page F-25
17.Please revise to include a description of tax years that remain subject to examination by
major tax jurisdictions in accordance with ASC 740-10-50-15(e).
14. Revenue and Segment Information, page F-27
18.You disclose that revenue within Asia contributed over 80% of your total revenue.  Please
revise to disclose revenues from external customers attributed to the your country of
domicile and attributed to all foreign countries in total in accordance with ASC 280-10-
50-41.  To the extent that revenues from external customers attributed to an individual
foreign country are material, disclose those revenues separately.
General
19.Please provide us with supplemental copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 January 25, 2023 Page 5
 FirstName LastName
Edwin Chun Yin Wong
J-Long Group Ltd
January 25, 2023
Page 5
behalf, have presented or expect to present to potential investors in reliance on Section
5(d) of the Securities Act, whether or not you retained, or intend to retain, copies of
those communications. Please contact the staff member associated with the review of this
filing to discuss how to submit the materials, if any, to us for our review
            You may contact Stephen Kim at 202-551-3291 or Linda Cvrkel at 202-551-3813 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services