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 March 20, 2025

Junjie Zhang
Chief Executive Officer
Chagee Holdings Limited
Tower B, Hongqiao Lianhe Building
No. 99 Kaihong Road
Changning District, Shanghai
People s Republic of China, 200051

 Re: Chagee Holdings Limited
 Amendment No. 7 to Draft Registration Statement on Form F-1
 Submitted March 11, 2025
 CIK No. 0002013649
Dear Junjie Zhang:

 We have reviewed your amended draft registration statement and have the
following
comment(s).

 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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 7 to Draft Registration Statement on Form F-1 submitted March 11,
2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Measure
Adjusted Net (Loss)/Income, page 91

1. Please tell us and expand your disclosure to explain why there is no tax
effect on the
 non-GAAP adjustments.
 March 20, 2025
Page 2
General

2. We note the changes you made to your disclosure appearing on the cover
page,
 summary risk factors, and risk factors sections relating to legal and
operational risks
 associated with operating in China and PRC regulations. It is unclear to
us that there
 have been changes in the regulatory environment in the PRC since the
amendment
 that was submitted on January 13, 2025, warranting revised disclosure to
mitigate the
 challenges you face and related disclosures. The Sample Letters to
China-Based
 Companies sought specific disclosure relating to the risk that the PRC
government
 may intervene in or influence your operations at any time, or may exert
control over
 operations of your business, which could result in a material change in
your
 operations and/or the value of the securities you are registering for
sale. The Sample
 Letters also sought specific disclosures relating to uncertainties
regarding the
 enforcement of laws and that the rules and regulations in China can
change quickly
 with little advance notice. We do not believe that your revised
disclosure conveys the
 same risks. Please restore your disclosure in these areas to the
disclosures as they
 existed in the draft registration statement as of January 13, 2025.

 Please contact Stephen Kim at 202-551-3291 or Suying Li at 202-551-3335
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Taylor Beech at 202-551-4515 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Li He
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