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Agencia Comercial Spirits Ltd

September 26, 2025

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Attention:
    Amy Geddes

    Angela Lumley

    Alyssa Wall

    Taylor Beech

    Re:

    Agencia Comercial Spirits Ltd

    Registration Statement on Form F-1, as amended
    (File No. 333- 288600)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of the
General Rules and Regulations (“Rule 461”) under the Securities Act of 1933, as amended, Agencia Comercial Spirits Ltd (the
“Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action
to cause the above-referenced Registration Statement on Form F-1, as amended (the “Registration Statement”) to become effective
at 4:00 p.m., Eastern Time, on Tuesday, September 30, 2025, or as soon thereafter as practicable.

If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. Such request may be made
by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Concord & Sage PC.

The Company understands that
the representative of the underwriters, on behalf of the prospective underwriters of the offering, has joined in this request in a separate
letter filed with the Commission today.

The Company understands that
the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the
fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the
securities specified in the Registration Statement.

    Very truly yours,

    Agencia Comercial Spirits Ltd

    /s/ Tsai Yi Yang

    Name:
    Tsai Yi Yang

    Title:
    Chief Executive Officer