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Huachen AI Parking Management Technology Holding
Co., Ltd

No.1018 Haihe Road, Dushangang Town

Pinghu City, Jiaxing

Zhejiang Province, China 314205

August 14, 2024

VIA EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    SiSi Cheng

    Andrew Blume

    Bradley Ecker

    Jennifer Angelini

    Re:
    Huachen AI Parking Management Technology Holding Co., Ltd

    Amendment No. 2 to Draft Registration Statement on Form F-1

    Submitted July 3, 2024

    CIK No. 0001958399

Ladies and Gentlemen:

This letter is being submitted in response to
the letter dated July 17, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff
of the Commission (the “Staff”) commented on the above-referenced Amendment No. 2 to Draft Registration Statement on
Form F-1 submitted on July 3, 2024. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amendment to the
Draft Registration Statement on Form F-1 (“F-1”) for submission with the Commission, which has been revised to reflect
the Staff’s comments as well as certain other updates to the F-1.

For the Staff’s convenience, each Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in F-1. Capitalized terms used but not otherwise defined herein have the
meanings set forth in the F-1.

Amendment No. 2 to Draft Registration Statement
on Form F-1

Capitalization, page 47

 1. We note your updated presentation in response to prior comment 4 and reissue our comment. Please limit
the liability section of your capitalization table to only include your short- and long-term bank loans.

RESPONSE: We note the Staff’s comment, and, in response hereto, respectfully
advise the Staff that we have revised on pages 47 of the F-1 to limit the liability section of the capitalization table to only include
our short- and long-term bank loans.

Business, page 65

 2. We note your updated disclosure in response to prior comment 5 and reissue our comment. As your 2022
revenue percentages disclosed in the table on page 65 still appear incorrect, please revise your filing accordingly.

RESPONSE: We note the Staff’s comment, and, in response hereto, respectfully
advise the Staff that we have revised our 2022 revenue percentage on pages 65 of the F-1.

General

 3. We note disclosure on page 52 regarding a shift in your business (with cubic parking garage revenues
representing 23% in 2023 compared with 81% in 2022, and equipment structural parts revenues representing 75% in 2023 compared with 16%
in 2022).

Please address the following items:

 · Revise the business section to more fully
describe your equipment structural parts business, providing an analogous level of detail as provided for your cubic parking garage business.
Include, without limitation, discussion regarding manufacturing, marketing and sales, and customers for equipment structural parts.

 · Further describe the “real estate policy
regulation” disclosed as the reason for your business shift, clarifying whether and how the regulation limits your cubic parking
garage business.

 · Disclose whether the business shift is expected
to be permanent, temporary, or variable from period-to-period, identifying and discussing the main factors that influence your decision
to scale operations up or down.

 · As appropriate, revise disclosure throughout
the prospectus that presents your company as a “smart parking solutions provider” to provide a more balanced description as
an equipment structural parts provider.

RESPONSE: We note the Staff’s
comment, and, in response hereto, respectfully advise the Staff that:

 · We have revised on pages 79 and 82 to 85 of the F-1 to disclose the
suppliers, sales and marketing, and manufacturing process of our equipment structural parts business. We have previously disclosed the
customers of our equipment structural parts business on pages 2, 49 and 65 of the F-1.

 · We have revised on page 52 of the F-1 to include the reason for our
business shift in the fiscal year of 2023, and clarified how the regulation limited our cubic parking garage business for the fiscal year
of 2023.

 · We have revised on page 52 of the F-1 to disclose that we do not expect
the business shift to be permanent and the factors we may consider to scale our operations up or down.

 · We have revised on pages 2, 49 and 65 of the F-1 to disclose that we
are a comprehensive smart parking solutions and equipment structural parts provider.

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We hope this response has addressed all of
the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained
herein, please contact our outside securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yuning
“Grace” Bai, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or gbai@orllp.legal.

Very truly yours,

    By:
    /s/ Bin Lu

    Name:
     Bin Lu

    Title:
    Chief Executive Officer

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