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 HW Electro Co., Ltd.

 June 2, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Manufacturing

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:

 Kevin Woody
 SiSi Cheng

 Asia Timmons-Pierce
 Evan Ewing

 Re:
 HW Electro Co., Ltd.

 Registration Statement on Form F-1

 Filed May 9, 2025

 File No. 333-287112
 CIK No. 0001980262

 Ladies and Gentlemen:

 This letter is in response to the letter dated
May 16, 2025, 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. 1 to the Registration Statement on Form F-1
("Amendment No. 1") is being filed to accompany this letter.

 Registration Statement on Form F-1 filed
May 9, 2025

 Capitalization, page 39

 1. It does not appear the non-current portion
of your loans payable to third party is included in your capitalization table. Please revise or advise.

 In response to the Staff's comments, we
revised our disclosure on page 39 of Amendment No. 1 to include the non-current portion of our loans payable to third party in our capitalization
table.

 Dilution, page 41

 2. Please explain to us how the short-term
loan obtained after September 2024 increased your pro forma net tangible book value. In this regard, we note that net tangible book value
is calculated as total tangible assets less total liabilities. In addition, please tell us how you considered excluding deferred offering
costs from the historical, pro forma and pro forma as adjusted net tangible book value amounts.

 In response to the Staff's comments, we
revised our disclosure from pages 39 to page 42 of Amendment No. 1 to exclude short-term loan obtained after September 2024 from pro forma
and pro forma as adjusted net tangible book value amounts and the deferred offering costs from the historical, pro forma and pro forma
as adjusted net tangible book value amounts.

 Management's Discussion and Analysis of
Financial Condition and Results of Operations

 Results of Operations, page 47

 3. Please revise to provide a more comprehensive
discussion and analysis of the factors that impacted your results between comparative periods for all periods presented, including a discussion
of any known trends or uncertainties that are reasonably expected to impact near and long-term results. Refer to Item 303(b)(2) of Regulation
S-K and Commission Release No. 33-8350.

 In response to the Staff's comments,
we revised our disclosure from pages 44 to 50 of Amendment No. 1 to provide a more comprehensive discussion and analysis of the
factors that impacted our results between comparative periods for all periods presented, including a discussion of any known trends
or uncertainties that are reasonably expected to impact our near and long-term results.

 Cash Flows

 Cash Flow from Operating Activities, page
55

 4. Your net cash used in operating activities
appears to have decreased by $11.5 million during fiscal year 2024 as opposed to $1.1 million as you disclosed on page 55. Please advise
or revise.

 In response to the Staff's comments, we
revised our disclosure on page 56 of Amendment No. 1 to revise the number from $1.1 million to $11.5 million.

 General

 5. Please revise Exhibit 5.1 to cover the shares
that may be sold pursuant to the over-allotment option.

 In response to the Staff's comments, we
revised Exhibit 5.1 to cover the shares that may be sold pursuant to the over-allotment option.

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 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

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