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HW Electro Co., Ltd.

December 23, 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:

    Andrew Blume

    SiSi Cheng

    Asia Timmons-Pierce

    Evan Ewing

    Re:
    HW Electro Co., Ltd.

    Registration Statement on Form F-1

    Filed December 10, 2024

    File No. 333-278974

    CIK No. 0001980262

Ladies and Gentlemen:

This letter is in response to the letter dated
December 20, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HW Electro Co., Ltd. (the “Company,” “we,” and “our”). For ease of reference, we have
recited the Commission’s comments in this response and numbered them accordingly. An amendment No. 3 to the Registration Statement
on Form F-1 (“Amendment No. 3”) is being filed to accompany this letter.

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

Cover Page

1. We note your disclosure on page 26 that
"[w]e anticipate that our directors and executive officers will together beneficially own approximately 54.6% of our Ordinary Shares
issued and outstanding after the completion of this offering, excluding shares issuable upon exercise of unexercised options," however,
your principal shareholders table on page 98 states that the amount of beneficially owned ordinary shares after the offering by the directors
and senior management as a group will be 41.6%. Please revise or clarify. If true, please also revise the cover page to disclose that
the company will be a controlled by the directors and executive officers post-offering, identify the controlling stockholder(s) and such
stockholders’ total voting power, and include appropriate risk factor disclosure.

In response to the Staff’s comments,
we respectfully advise the Staff that our directors and executive officers will together beneficially own approximately 41.6% of our
ordinary shares issued and outstanding after the completion of this offering, excluding shares issuable upon exercise of unexercised
options. We revised our disclosure on page 26 of the Amendment No. 3 to amend the percentage of shares owned by our directors and executive officers after the completion of this offering.

Compensation, page 96

2. Please update your compensation disclosure
to reflect the fiscal year ended September 30, 2024.

In response to the Staff’s comments, we
revised our disclosure on page 97 of the Amendment No. 3 to update our compensation disclosure to reflect the fiscal year ended September
30, 2024.

Related Party Transactions, page 100

3. Please revise your disclosure in this section
to provide information up to a more recent date as required by Item 7.B of Form 20-F.

In response to the Staff’s comments, we
revised our disclosure from pages 100 to 103 of the Amendment No. 3 to provide information up to a more recent date as required by Item
7.B of Form 20-F.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Weicheng Hsiao

    Name:
    Weicheng Hsiao

    Title:
    Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC