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CORRESP
1
filename1.htm

September
9, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

100
F Street, NE

Washington,
D.C. 20549

Attn:
Ms. Liz Packebusch and Ms. Irene Barberena-Meissner

Re:
New Century Logistics (BVI) Ltd

Amendment
No. 5 to Registration Statement on Form F-1

Filed
August 14, 2024

File
No. 333-274115

Dear
Ms. Liz Packebusch and Ms. Irene Barberena-Meissner:

Please
find below our responses to the questions raised by the staff of the Securities and Exchange Commission (the “Commission”)
in its letter of comments dated September 5, 2024, relating to the above-referenced Registration Statement filed by New Century Logistics
(BVI) Ltd (the “Company” or “we”).

The
Company’s responses are numbered to correspond to the staff’s comments.

We
have also updated the Registration Statement which is filed with the Commission simultaneously together with this letter.

    1.
    We
                                            note your disclosure here that you and all of your directors and officers and certain shareholders
                                            (5% or more shareholders) have agreed with the Underwriter, subject to certain exceptions,
                                            not to sell, transfer, or dispose of, directly or indirectly, any of your Ordinary Shares
                                            or securities convertible into or exercisable or exchangeable for your Ordinary Shares for
                                            a period of six (6) months after the date of this prospectus. This appears inconsistent with
                                            your disclosure at pages 119 and 126, which states that you have agreed not to, for a period
                                            of six (6) months from the effective date of the registration statement of which this prospectus
                                            forms a part, offer, issue, sell, contract to sell, encumber, grant any option for the sale
                                            of, or otherwise dispose of, except in this offering, any of your Ordinary Shares or securities
                                            that are substantially similar to your September 5, 2024 Ordinary Shares. Please revise your
                                            disclosure to clarify when each applicable lock-up period begins for each respective party.

    Response
    The
    Registration Statement has been revised to disclose consistently throughout each applicable lock-up period in accordance with the
    staff’s comment.

Should
you have any questions regarding the foregoing, please do not hesitate to contact me or our counsel.

    Very
    truly yours,

    By:
    /s/
    Ngan Ching Shun

    Name:

    Ngan
    Ching Shun

    Chief
    Executive Officer