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ANEW Health Limited

Unit 2301-05, 23/F, Tower 5, The Gateway

Harbour City, 15 Canton Road

Tsim Sha Tsui, Kowloon, Hong Kong

April 16, 2025

VIA EDGAR

Office of Industrial Applications and Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    RE:
    ANEW Health Limited

    Registration Statement on Form F-1

    Filed March 31, 2025

    File No. 333-285657

Dear Ms. Jane Park, Ms. Tayyaba Shafique, Mr.
Conlon Danberg, Mr. Terence O’Brien:

We are in receipt of the comment letter dated
April 4, 2025, regarding ANEW Health Limited (the “Company,” “Anew Health,” or “we”) from the U.S.
Securities and Exchange Commission staff (the “Staff”). An Amended Registration Statement on Form F-1 (the “Form F-1/A”),
which has been revised to reflect the Staff’s comments as well as certain other updates to
the Form F-1/A, is being submitted confidentially to accompany this letter. As requested by the Staff, we have provided responses
to the questions raised by the Staff.

For the Staff’s convenience, the 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 Form F-1/A. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Form F-1/A.

Form F-1/A filed March 31, 2025

Note 2 - Summary of Significant Accounting
Policies

Revenue Recognition, page F-35

    1.
    We note your response to prior comment 2. Please tell us what consideration you gave to presenting disaggregated revenue by group of similar products and services within your financial statement footnotes as prescribed by ASC 280-10-50-40, similar to the presentation in your results of operations discussion on page 64. See also guidance for disaggregated revenue presentation in ASC 606-10-50-5..

RESPONSE: In response to the Staff’s
comment, we respectfully advise the Staff that disaggregated revenue by group of similar products and services is presented in page F-20
and F-44 as prescribed by ASC 280-10-50-40.

As prescribed by ASC 606-10-55-91, when selecting
the type of category (or categories) to use to disaggregate revenue, examples of categories that might be appropriate include, but are
not limited to, all of the following::

 a) Type of good or service (for example, major product lines)

 b) Geographical region (for example, country or region)

 c) Market or type of customer (for example, government and nongovernment customers)

 d) Type of contract (for example, fixed-price and time-and-materials contracts)

 e) Contract duration (for example, short-term and long-term contracts)

 f) Timing of transfer of goods or services (for example, revenue from goods or services transferred to customers
at a point in time and revenue from goods or services transferred over time)

 g) Sales channels (for example, goods sold directly to consumers and goods sold through intermediaries).

The Company analyze these factors for Pain Management
and Health Services Income – Energy based treatment, Pain Management and Health Services Income – Non energy-based treatment
and Healthcare Product Sales Income below:

    Pain Management and Health Services

 Income
    Healthcare Product Sales

 Income

    Factor
    Energy based

 treatment
    Non energy-based

 treatment

    a)
    Type of good or service
    “RDS+” (Restore, Detox, and Strengthen) approach-based service
    “RDS+” (Restore, Detox, and Strengthen) approach-based service
    Creams, moisturizers, ointments and dietary supplement

    b)
    Geographical region
    Hong Kong
    Hong Kong
    Hong Kong

    c)
     Market or type of customer
    Individuals
    Individuals
    Individuals

    d)
    Type of contract
    Fixed-price
    Fixed-price
    Fixed-price

    e)
    Contract duration
    1 year to 5 years
    1 year to 5 years
    End upon product delivery

    f)
    Timing of transfer of goods or services
    At a point in time
    At a point in time
    At a point in time

    g)
    Sales channels
    Through service centers in Hong Kong
    Through service centers in Hong Kong
    Through service centers in Hong Kong

From the above analysis, Pain Management and Health
Services Income - Energy based treatment and Pain Management and Health Services Income - Non energy-based treatment should be aggregated
per factors prescribed by ASC 606-10-55-91; whereas Healthcare Product Sales Income is distinct from Pain Management and Health Services
Income thus should be presented separately. The Company has revised page 64 and 65 accordingly.

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 the Company’s 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,

    /s/ Ka Wai Victor Mo

    Ka Wai Victor, MO

    Chief Executive Officer and Chairman of the
    Board