SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 24, 2025

Wallace Lee
Chief Financial Officer
Bon Natural Life Limited
Room 601, Block C, Gazelle Valley , No.69, Jinye Road
High-Tech Zone , Xi an , Shaanxi, China
People s Republic of China

 Re: Bon Natural Life Limited
 Form 20-F for Fiscal Year Ended September 30, 2024
 File No. 001-40517
Dear Wallace Lee:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Mark
 E. Crone
 Managing
 Partner
 mcrone@cronelawgroup.com

 April
16, 2025

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Life Sciences

 100
F Street, N.E.

 Washington,
DC 20549

 Attn:
Tana Harkins

 Lynn
Dicker

 Daniel
Crawford

 Laura
Crotty

 Re:
 Bon
 Natural Life Limited

 Form
 20-F for Fiscal Year Ended September 30, 2025

 File
 No. 001-40517

 Dear
Sir and Madam:

 On
behalf of Bon Natural Life Limited, a Cayman Islands exempted company (the "Company"), we hereby submit to the Securities
and Exchange Commission (the "Commission") this correspondence in response to the comments of the staff (the "Staff"),
dated March 24, 2025, with reference to the Company's Annual Report for the fiscal year ended September 30, 2024 on Form 20-F submitted
to the Commission on January 28, 2025.

 For
the convenience of the Staff, each of the Staff's comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to "we," "us" and "our" refer to
the Company on a consolidated basis.

 Form
20-F for Fiscal Year Ended September 30, 2024

 Item
3. Key Information

 Holding
Foreign Companies Accountable Act, page 3

 1.
 We
 note your disclosure on page 3 that "[yo]ur auditor, located in China, is subject to the 2021 Determination Report" appears
 to conflict with your disclosure on the same page stating your auditor "is a U.S.-based accounting firm that is registered
 with the PCAOB" and "was not subject to the 2021 Determination Report." Please revise to reconcile your disclosure
 or otherwise advise.

 Response:
 In response to the Staff's comment, we respectfully advise that Staff that the typographical error has been corrected on page
3. Additionally, we advise the Staff that the Company's clawback policy has been added as exhibit 99.1 to the amended Annual Report.

 We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

 Sincerely,

 THE CRONE LAW GROUP, P.C.

 /s/ Joe Laxague

 Joe Laxague, Esq.

 cc:
Yongwei Hu

 420 Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

 12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 24, 2025

Wallace Lee
Chief Financial Officer
Bon Natural Life Limited
Room 601, Block C, Gazelle Valley , No.69, Jinye Road
High-Tech Zone , Xi an , Shaanxi, China
People s Republic of China

 Re: Bon Natural Life Limited
 Form 20-F for Fiscal Year Ended September 30, 2024
 File No. 001-40517
Dear Wallace Lee:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
 March 24, 2025
Page 2
Form 20-F for Fiscal Year Ended September 30, 2024
Item 3. Key Information
Holding Foreign Companies Accountable Act, page 3

1. We note your disclosure on page 3 that [yo]ur auditor, located in
China, is subject to
 the 2021 Determination Report appears to conflict with your
disclosure on the same
 page stating your auditor is a U.S.-based accounting firm that is
registered with the
 PCAOB and was not subject to the 2021 Determination Report.
Please revise to
 reconcile your disclosure or otherwise advise.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Tara Harkins at 202-551-3639 or Lynn Dicker at
202-551-3616 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Crawford at 202-551-7767 or Laura Crotty at 202-551-7614 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 March
14, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Bon
 Natural Life Limited

 Registration
 Statement on Form F-1, as amended

 File
 No. 333-283333

 Request
 for Acceleration of Effective Date

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the " Securities Act "),
Univest Securities, LLC, as placement agent, hereby joins in the request of Bon Natural Life Limited for acceleration of the effective
date of the above-referenced registration statement on Form F-1, as amended (the " Registration Statement "), so that
it becomes effective as of 5:00 p.m. Eastern Time on Friday, March 14, 2025, or as soon thereafter as possible.

 The
undersigned has and will comply, and it has been informed or will be informed by any participating dealers that they have complied or
will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [Signature
Page to Follow]

 Very truly yours,

 UNIVEST SECURITIES, LLC

 By:
 /s/ Edric Yi Guo

 Name:
 Edric Yi Guo

 Title:
 CEO and Head of Investment Banking

 [Signature
Page to Placement Agent's Acceleration Request]

CORRESP
 1
 filename1.htm

 Bon
Natural Life Limited

 C601,
Gazelle Valley, No.69 Jinye Road.

 Xi'an
Hi-tech Zone, Xi'an, China

 March 14, 2025

 VIA
EDGAR

 Securities
and Exchange Commission

 Division
of Corporation Finance

 100
F Street N.E.

 Washington,
D.C. 20549

 Re:

 Bon
 Natural Life Limited

 Registration
 Statement on Form F-1

 File
 No. 333- 283333

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Bon Natural Life Limited, hereby respectfully requests acceleration
of the effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 5:00
p.m. Eastern Time, on Friday, March 14, 2025, or as soon as practicable thereafter.

 Very truly yours,

 Bon Natural Life Limited

 By:
 /s/
 Yongwei Hu

 Yongwei Hu

 Chief
 Executive Officer

CORRESP
 1
 filename1.htm

 Mark
 E. Crone
 Managing
 Partner
 mcrone@cronelawgroup.com

 March
13, 2025

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Life Sciences

 100
F Street, N.E.

 Washington,
DC 20549

 Attn:
Daniel Crawford

 Joe
McCann

 John
Coleman

 Re:
 Bon
 Natural Life Limited

 Amendment
 No. 4 to Registration Statement on Form F-1

 Submitted
 March 3, 2025

 File
 No. 333-283333

 Dear
Sir and Madam:

 On
behalf of Bon Natural Life Limited, a Cayman Islands exempted company (the "Company"), we hereby file with the Securities
and Exchange Commission (the "Commission") an amended registration statement on Form F-1 (the "Amended Registration
Statement") in response to the comments of the staff (the "Staff"), dated March 10, 2025, with reference to the Company's
Amendment No. 3 to Registration Statement on Form F-1 submitted to the Commission on March 3, 2025.

 For
the convenience of the Staff, each of the Staff's comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to "we," "us" and "our" refer to
the Company on a consolidated basis.

 Amendment
No. 3 to Registration Statement on Form F-1

 General

 1.
 We
 note your references throughout the prospectus to an "alternative cashless exercise provision." The term "cashless
 exercise" is generally understood to allow a warrant holder to exercise a warrant without paying cash for the exercise price
 and reducing the number of shares receivable by the holder by an amount equal in value to an aggregate exercise price the holder
 would otherwise pay to exercise the warrant(s). In cashless exercises, it is expected that the warrant holder receives fewer shares
 than they would if they opted to pay the exercise price in cash. Please clarify your disclosure by removing the references to "alternative
 cashless exercise" and using the term "zero exercise price" exclusively..

 Response:
 The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page and pages 6, 37
and 100.

 420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891
 12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025
| 818-930-5686

 We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

 Sincerely,

 THE CRONE LAW GROUP, P.C.

 /s/
Joe Laxague

 Joe
Laxague, Esq.

 cc:
Yongwei Hu

 420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891
 12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025
| 818-930-5686

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 10, 2025

Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
C601, Gazelle Valley, No.69 Jinye Road
Xi an Hi-tech Zone, Xi an, China

 Re: Bon Natural Life Limited
 Registration Statement on Form F-1
 Response dated March 5, 2025
 File No. 333-283333
Dear Yongwei Hu:

 We have reviewed your amended registration statement and have the
following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our March 4,
2025 letter.

Amendment No. 3 to Registration Statement on Form S-1
General

1. We note your references throughout the prospectus to an alternative
cashless exercise
 provision. The term cashless exercise is generally understood
to allow a warrant
 holder to exercise a warrant without paying cash for the exercise price
and reducing
 the number of shares receivable by the holder by an amount equal in
value to an
 aggregate exercise price the holder would otherwise pay to exercise the
warrant(s). In
 cashless exercises, it is expected that the warrant holder receives
fewer shares than
 they would if they opted to pay the exercise price in cash. Please
clarify your
 disclosure by removing the references to alternative cashless
exercise and using the
 term zero exercise price exclusively.
 March 10, 2025
Page 2

 Please contact Daniel Crawford at 202-551-7767 or Joe McCann at
202-551-6262
with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
cc: Cassi Olson, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

March
5, 2025

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

Attn:
Daniel Crawford

Joe
McCann

John
Coleman

    Re:
    Bon
    Natural Life Limited

    Amendment
    No. 3 to Registration Statement on Form F-1

    Submitted
    March 3, 2025

    File
    No. 333-283333

Dear
Sir and Madam:

On
behalf of Bon Natural Life Limited, a Cayman Islands exempted company (the “Company”), we hereby submit to the Securities
and Exchange Commission (the “Commission”) this correspondence in response to the comments of the staff (the “Staff”),
dated March 4, 2025, with reference to the Company’s Amendment No. 3 to Registration Statement on Form F-1 submitted to the Commission
on March 3, 2025.

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

Amendment
No. 3 to Registration Statement on Form F-1

Cover
Page

    1.
    We
    note your amended disclosure and response to prior comment 2 and reissue in part. It appears that the exercise price of your Series
    B Warrants could increase, and if it were to do so, then there could be more than 130,000,000 Class A Ordinary Shares underlying
    the Series B Warrants. Please advise or revise the header, the cover page narrative and the Summary to highlight the maximum number
    of shares that could be issued upon exercise of your Series B warrants. For guidance, refer to Regulation S-K, Item 501(b)(2).

Response:
In response to the Staff’s comment, we respectfully advise the Staff that the Company and Univest Securities, LLC represent
and warrant to the Staff that the initial exercise price and floor price set with respect to the Series B Warrants in the offering will
be at prices to ensure that the maximum number of Class A Ordinary Shares issuable under the Series B Warrants will not exceed 130,000,000
shares.

420
                                            Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121
Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

  Sincerely,

  THE CRONE LAW GROUP, P.C.

  /s/ Joe Laxague

  Joe Laxague, Esq.

cc:
Yongwei Hu

420
Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121
Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

March 4, 2025
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
C601, Gazelle Valley, No.69 Jinye Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Amendment No. 3 to Registration Statement on Form F-1
Filed March 3, 2025
File No. 333-283333
Dear Yongwei Hu:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our February 24, 2025 letter.
Amendment No. 3 to Registration Statement on Form F-1
Cover Page
1.We note your amended disclosure and response to prior comment 2 and reissue in
part. It appears that the exercise price of your Series B Warrants could increase, and if
it were to do so, then there could be more than 130,000,000 Class A Ordinary Shares
underlying the Series B Warrants. Please advise or revise the header, the cover page
narrative and the Summary to highlight the maximum number of shares that could be
issued upon exercise of your Series B warrants. For guidance, refer to Regulation S-K,
Item 501(b)(2).

March 4, 2025
Page 2
            Please contact Daniel Crawford at 202-551-7767 or Joe McCann at 202-551-6262
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Cassi Olson, Esq.

CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

March
3, 2025

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

Attn:
Daniel Crawford

Joe
McCann

John
Coleman

    Re:
    Bon
    Natural Life

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

    Submitted
    February 18, 2025

    File
    No. 333-283333

Dear
Sir and Madam:

On
behalf of Bon Natural Life, a Cayman Islands exempted company (the “Company”), we are concurrently with this letter filing
with the Securities and Exchange Commission (the “Commission”) Amendment No. 3 to Registration Statement on Form F-1 (“Amendment
No. 3”) in response to the comments of the staff (the “Staff”), dated February 24, 2025, regarding the Company’s
above referenced Amendment No. 2 to Registration Statement on Form F-1 filed with the Commission on February 18, 2025.

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

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

Cover
Page

    1.
    We
    note your response to comment 1 and reissue. Please revise your Cover Page headings to reflect that you also are registering 5,000,000
    Class A Ordinary Shares in addition to the 5,000,000 Class A Ordinary Shares underlying the Pre-Funded Warrants and the 10,000,000
    Class A Ordinary Shares underlying the Series A and B Warrants.

Response:
We have revised the cover page in Amendment No. 3 in response to the Staff’s comments.

420
Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121
Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

    2.
    We
    note your revised disclosures indicating that your Series A and Series B warrants contain reset and/or alternative cashless exercise
    features that could result in the warrant holders potentially receiving a significant number of Class A Ordinary Shares in excess
    of the 10,000,000 shares highlighted in the header. Given these provisions, please revise the header, the cover page narrative and
    the Summary to highlight the maximum number of shares that could be issued upon exercise of (i) your Series A warrants and (ii) your
    Series B warrants. For guidance, refer to Regulation S-K, Item 501(b)(2).

Response:
Amendment No. 3 has been revised in response to the Staff’s comments on the cover page and page 6 with respect to the Series
B Warrants. Further, we respectfully advise the Staff that the alternative cashless exercise feature is only applicable to the Series
B Warrants and as such, we have disclosed the maximum number of shares issuable under the alternative cashless exercise provision
of the Series B Warrants using the floor price stated therein. No additional Class A Ordinary Shares are issuable with respect
to any exercise price reset features of either the Series A Warrants or the Series B Warrants.

 3. With
                                            respect to the warrants with an alternative cashless exercise feature, please revise the
                                            cover page narrative and Summary to explain, if true, that as a result of this feature you
                                            do not expect to receive any cash proceeds from the exercise of the Warrants because it is
                                            highly unlikely that a warrant holder would wish to pay an exercise price to receive one
                                            share when they could choose the alternative cashless exercise option and pay no money to
                                            receive more than one share.

Response:
Amendment No. 3 has been revised in response to the Staff’s comments on the cover page and page 6.

We
hope Amendment No. 3 to the Registration Statement addresses the Staff’s comments. If we can provide any further assistance, please
do not hesitate to contact the undersigned.

    Sincerely,

    THE
    CRONE LAW GROUP, P.C.

    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

cc:
Yongwei Hu

420
Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121
Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

February 24, 2025
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
C601, Gazelle Valley, No.69 Jinye Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed February 18, 2025
File No. 333-283333
Dear Yongwei Hu:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our January 27, 2025 letter.
Amendment No. 2 to Registration Statement on Form F-1
Cover Page
1.We note your response to comment 1 and reissue. Please revise your Cover Page
headings to reflect that you also are registering 5,000,000 Class A Ordinary Shares in
addition to the 5,000,000 Class A Ordinary Shares underlying the Pre-Funded
Warrants and the 10,000,000 Class A Ordinary Shares underlying the Series A and B
Warrants.
We note your revised disclosures indicating that your Series A and Series B warrants
contain reset and/or alternative cashless exercise features that could result in the
warrant holders potentially receiving a significant number of Class A Ordinary Shares
in excess of the 10,000,000 shares highlighted in the header. Given these provisions,
please revise the header, the coverpage narrative and the Summary to highlight the 2.

February 24, 2025
Page 2
maximum number of shares that could be issued upon exercise of (i) your Series A
warrants and (ii) your Series B warrants. For guidance, refer to Regulation S-K, Item
501(b)(2).
3.With respect to the warrants with an alternative cashless exercise feature, please
revise the coverpage narrative and Summary to explain, if true, that as a result of this
feature you do not expect to receive any cash proceeds from the exercise of the
Warrants because it is highly unlikely that a warrant holder would wish to pay an
exercise price to receive one share when they could choose the alternative cashless
exercise option and pay no money to receive more than one share.
            Please contact Daniel Crawford at 202-551-7767 or Joe McCann at 202-551-6262
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Cassi Olson, Esq.

CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

February
18, 2025

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

Attn:
Daniel Crawford

Joe
McCann

John
Coleman

    Re:
    Bon
    Natural Life

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

    Submitted
    January 16, 2025

    File
    No. 333-283333

Dear
Sir and Madam:

On
behalf of Bon Natural Life, a Cayman Islands exempted company (the “Company”), we are concurrently with this letter filing
with the Securities and Exchange Commission (the “Commission”) Amendment No. 2 to Registration Statement on Form F-1
(“Amendment No. 2”) in response to the comments of the staff (the “Staff”), dated January 27, 2025, regarding
the Company’s above-referenced Amendment No. 1 to Registration Statement on Form F-1 filed with the Commission
on January 16, 2025.

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

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

Cover
Page

    1.
    We
    note your response to prior comment 1 and amended disclosure stating you are now offering Ordinary Units. Please revise the cover
    page caption to clarify that you are registering up to 15,000,000 Class A Ordinary Shares, including the shares underlying the Pre-Funded
    Warrants and Series A and B Warrants, as some of the Ordinary Shares are not dependent on exercising the Warrants.

Response:
In response to the Staff’s comments, we have made clarifying changes on the front and cover pages of
Amendment No. 2.

420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 |
818-930-5686

    2.
    We
    note your disclosure that your “offering may be extended by written agreement of the Company and the placement agent”.
    Please revise to provide a certain date your offering will terminate. Refer to Item 501(b)(8)(iii) of Regulation S-K.

Response:
In response to the Staff’s comment, we have revised the cover page of Amendment No. 2.

We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

    Sincerely,

    THE
    CRONE LAW GROUP, P.C.

    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

    cc:
    Yongwei Hu

420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 |
818-930-5686

January 27, 2025
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
C601, Gazelle Valley, No.69 Jinye Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Amendment No. 1 to Registration Statement on Form F-1
Filed January 16, 2025
File No. 333-283333
Dear Yongwei Hu:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our November 26,
2024 letter.
Amendment No. 1 to Registration Statement on Form F-1
Cover Page
1.We note your response to prior comment 1 and amended disclosure stating you are
now offering Ordinary Units. Please revise the cover page caption to clarify that you
are registering up to 15,000,000 Class A Ordinary Shares, including the shares
underlying the Pre-Funded Warrants and Series A and B Warrants, as some of the
Ordinary Shares are not dependent on exercising the Warrants.
2.We note your disclosure that your "offering may be extended by written agreement of
the Company and the placement agent." Please revise to provide a certain date your
offering will terminate. Refer to Item 501(b)(8)(iii) of Regulation S-K.

January 27, 2025
Page 2
            Please contact Daniel Crawford at 202-551-7767 or Suzanne Hayes at 202-551-3675
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Cassi Olson, Esq.

CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

January
16, 2025

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

Attn:
Daniel Crawford

Joe
McCann

John
Coleman

    Re:
    Bon
    Natural Life

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

    Submitted
    November 19, 2024

    File
    No. 333-283333

Dear
Sir and Madam:

On
behalf of Bon Natural Life, a Cayman Islands exempted company (the “Company”), we hereby file with the Securities and Exchange
Commission (the “Commission”) an amended registration statement on Form F-1 (the “Amended Registration Statement”)
in response to the comments of the staff (the “Staff”), dated November 26, 2024, with reference to the Company’s Registration
Statement on Form F-1 filed with the Commission on November 19, 2024.

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

Registration
Statement on Form F-1

Cover
Page

    1.
    Please
    revise your cover page heading to quantify the number of Ordinary Shares you are registering. Refer to item 501(b)(2) of Regulation
    S-K.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

420 Lexington Avenue, Suite 2446, New York,
NY 10170 | 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles,
CA 90025 | 818-930-5686

    2.
    We
    note your disclosure on page 7 that “ordinary shares started to trade on the Nasdaq Capital Market under the ticker symbol
    “BON” since June 24, 2021.” Please revise your cover page to disclose the markets for your securities. Refer to
    Item 501(b)(4) of Regulation S-K.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

Management

Compensation,
page 95

    3.
    Please
    revise to disclose the compensation of your executive officers and directors for your most recently completed financial year. Refer
    to Item 6.B of Form 20-F.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the page 98.

We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

  Sincerely,

  THE
  CRONE LAW GROUP, P.C.

  /s/ Joe Laxague

  Joe Laxague, Esq.

cc:
Yongwei Hui

420 Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

November 26, 2024
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
C601, Gazelle Valley, No.69 Jinye Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Registration Statement on Form F-1
Filed November 19, 2024
File No. 333-283333
Dear Yongwei Hu:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1
Cover Page
1.Please revise your cover page heading to quantify the number of Ordinary Shares
you are registering. Refer to item 501(b)(2) of Regulation S-K.
2.We note your disclosure on page 7 that "ordinary shares started to trade on the Nasdaq
Capital Market under the ticker symbol “BON” since June 24, 2021." Please revise
your cover page to disclose the markets for your securities. Refer to Item 501(b)(4) of
Regulation S-K.
Management
Compensation, page 95
3.Please revise to disclose the compensation of your executive officers and directors for
your most recently completed financial year. Refer to Item 6.B of Form 20-F.

November 26, 2024
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Daniel Crawford at 202-551-7767 or Joe McCann at 202-551-6262
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Cassi Olson, Esq.

United States securities and exchange commission logo
June 16, 2023
Wallace Lee
Chief Financial Officer
Bon Natural Life Limited
25F, Rongcheng Yungu
Keji 3rd Road
Xi'an Hi-Tech Zone
Xi'an, China
Re:Bon Natural Life Limited
Form 20-F for the Fiscal Year Ended September 30, 2022
File No. 001-40517
Dear Wallace Lee:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
filename1.htm

  Joe
                                            Laxague

Partner

jlaxague@cronelawgroup.com

VIA
EDGAR

May
15, 2023

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

  Attn:
  Arzhang Navai

    Re:
    Bon
                                            Natural Life Limited

    Form
    20-F for the Fiscal Year Ended September 30, 2022

    Filed
    February 10, 2023

    File
    No. 001-40517

Dear
Mr. Navai:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities and Exchange
Commission (the “Commission”) in its letter dated May 1, 2023, commenting on the Company’s Annual Report on Form 20-F
filed February 10, 2023 (the “Annual Report”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Form
20-F for the Fiscal Year Ended September 30, 2022

Part
I, Item 3. Key Information, page 2

1. At
the onset of Part I, Item 3 disclose prominently that you are not a Chinese operating company but a Cayman Islands holding company with
operations conducted by your subsidiaries based in China and that this structure involves unique risks to investors. Provide a cross-reference
to your detailed discussion of risks facing the company and the offering as a result of this structure.

Response:
In response to this comment, the Company has amended the Annual Report to add the requested disclosure at the outset of Part I, Item
3, and to include a cross-reference to the risks disclosed in detail under the heading “Risks Related to Our Corporate Structure.”

2. Please
provide prominent disclosure about the legal and operational risks associated with being based in or having the majority of the company’s
operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or
the value of your securities or could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should address how recent
statements and regulatory actions by China’s government, such as those related to data security or anti-monopoly concerns, have
or may impact the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.

Response:
In response to this comment, the Company has amended the Annual Report to add the requested disclosure near the beginning of Part I,
Item 3, and to include a cross-reference to the risks disclosed in detail under the heading “Risks Related to Legal Uncertainty
and Doing Business in China.”

Arzhang Navai

United States Securities and Exchange Commission

May
15, 2023

Page 2 of 3

3. Please
disclose whether your auditor is subject to the determinations announced by the PCAOB on December 16, 2021 and whether and how the Holding
Foreign Companies Accountable Act and related regulations will affect your company. Disclose that the HFCAA timeline for a potential
trading prohibition was shortened from three years to two years, as part of the “Consolidated Appropriations Act, 2023,”
signed into law on December 29, 2022. Also, revise your risk factor disclosure on page 17 to explain the shortened timeframe.

Response:
In response to this comment, the Company has amended the Annual Report to include a disclosure regarding the HFCAA, AHFCAA, and related
matters near the beginning of Part I, Item 3, and to disclose that the Company’s auditor is based in the U.S. and was not subject
to the PCAOB’s initial determination report in 2021. The risk factor on page 17 has also been updated to discuss the shortened
2-year time frame under legislation passed December 29, 2022.

4. Please
provide a clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings. Quantify
any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and direction
of transfer. Quantify any dividends or distributions that a subsidiary have made to the holding company and which entity made such transfer,
and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign
exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations
on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

Response:
In response to this comment, the Company has amended the Annual Report to include the requested disclosures near the beginning of Part
I, Item 3.

5. Disclose
each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer securities to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the China
Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is required to
approve your operations, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions
or approvals have been denied. Please also describe the consequences to you and your investors if you or your subsidiaries: (i) do not
receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or
(iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

Response:
In response to this comment, the Company has amended the Annual Report to include the requested disclosures near the beginning of Part
I, Item 3.

Arzhang Navai

United States Securities and Exchange Commission

May
15, 2023

Page
3 of 3

Item
3. Key Information, D. Risk Factors, page 3

6. At
the onset of your risk factor discussion, please add a risk factor that addresses your corporate structure and being based in or having
the majority of the company’s operations in China. Discuss the risks it poses to investors. In particular, describe the significant
regulatory, liquidity, and enforcement risks. For example, specifically discuss risks arising from the legal system in China, including
risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance
notice; and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over
offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations
and/or the value of your securities. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control
over offerings that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of your securities to significantly decline or
be worthless.

Response:
In response to this comment, the Company has amended the Annual Report to add the new risk factor described in this comment to the beginning
of the Risk Factors section,

Item
15. Controls and Procedures

A.
Disclosure Controls and Procedures , page 102

7. Item
15(a) of Form 20-F requires you to disclose the conclusions of your principal executive and principal financial officers, or persons
performing similar functions, regarding the effectiveness of your disclosure controls and procedures. Please note that disclosure controls
and procedures and internal control over financial reporting require two separate and distinct assessments and conclusions. Please amend
the filing to include management’s assessment of the effectiveness of disclosure controls and procedures as of September 30, 2022
as required by Item 15(a) of Form 20-F.

Response:
In response to this comment, the Company has amended the Annual Report to include the conclusions of management regarding the effectiveness
of the Company’s disclosure controls and procedures.

B.
Management’s Annual Report on Internal Control Over Financial Reporting, page 102

8. You
state this annual report does not include a report of management’s assessment regarding internal control over financial reporting
due to the transition period established by rules of the SEC for newly public companies. However, we note that you filed an annual report
on Form 20-F for the year ended September 30, 2021 pursuant to Section 13(a) or 15(d) of the Exchange Act. Please amend your filing to
include management’s report on internal control over financial reporting for the year ended September 30, 2022. Refer to Item 15(b)
and Instruction 1 to Item 15 of Form 20-F.

Response:
In response to this comment, the Company has amended the Annual Report to include management’s assessment of the Company’s
internal controls over financial reporting.

Exhibits

9. Your
certifications filed as Exhibit 31.1 and 31.2 appear to include modifications from the standard language, including paragraph 4(d). In
the amended filing and other future filings, please revise these certifications to include the exact language as provided in Exhibit
Instruction 12 to Form 20-F.

Response:
In response to this comment, the Company has amended Exhibits 31.1 and 31.2 to the Annual Report to conform to the exact language in
Exhibit Instruction 12 to Form 20-F.

Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.

    THE
    CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
May 1, 2023
Wallace Lee
Chief Financial Officer
Bon Natural Life Limited
25F, Rongcheng Yungu
Keji 3rd Road
Xi'an Hi-Tech Zone
Xi'an, China
Re:Bon Natural Life Limited
Form 20-F for the Fiscal Year Ended September 30, 2022
Filed February 10, 2023
File No. 001-40517
Dear Wallace Lee:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended September 30, 2022
Part I, Item 3. Key Information, page 2
1.At the onset of Part I, Item 3 disclose prominently that you are not a Chinese operating
company but a Cayman Islands holding company with operations conducted by your
subsidiaries based in China and that this structure involves unique risks to investors.
Provide a cross-reference to your detailed discussion of risks facing the company and the
offering as a result of this structure.
2.Please provide prominent disclosure about the legal and operational risks associated with
being based in or having the majority of the company’s operations in China. Your
disclosure should make clear whether these risks could result in a material change in your
operations and/or the value of your securities or could significantly limit or completely

 FirstName LastNameWallace Lee
 Comapany NameBon Natural Life Limited
 May 1, 2023 Page 2
 FirstName LastNameWallace Lee
Bon Natural Life Limited
May 1, 2023
Page 2
hinder your ability to offer or continue to offer securities to investors and cause the value
of such securities to significantly decline or be worthless. Your disclosure should address
how recent statements and regulatory actions by China’s government, such as those
related to data security or anti-monopoly concerns, have or may impact the company’s
ability to conduct its business, accept foreign investments, or list on a U.S. or other
foreign exchange.
3.Please disclose whether your auditor is subject to the determinations announced by the
PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies
Accountable Act and related regulations will affect your company. Disclose that the
HFCAA timeline for a potential trading prohibition was shortened from three years to two
years, as part of the "Consolidated Appropriations Act, 2023," signed into law on
December 29, 2022. Also, revise your risk factor disclosure on page 17 to explain the
shortened timeframe.
4.Please provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings. Quantify any cash flows and transfers of
other assets by type that have occurred between the holding company and its subsidiaries,
and direction of transfer. Quantify any dividends or distributions that a subsidiary have
made to the holding company and which entity made such transfer, and their tax
consequences. Similarly quantify dividends or distributions made to U.S. investors, the
source, and their tax consequences. Your disclosure should make clear if no transfers,
dividends, or distributions have been made to date. Describe any restrictions on foreign
exchange and your ability to transfer cash between entities, across borders, and to U.S.
investors. Describe any restrictions and limitations on your ability to distribute earnings
from the company, including your subsidiaries, to the parent company and U.S. investors.
5.Disclose each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business and to offer securities to foreign
investors. State whether you or your subsidiaries are covered by permissions requirements
from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of
China (CAC) or any other governmental agency that is required to approve your
operations, and state affirmatively whether you have received all requisite permissions or
approvals and whether any permissions or approvals have been denied. Please also
describe the consequences to you and your investors if you or your subsidiaries: (i) do not
receive or maintain such permissions or approvals, (ii) inadvertently conclude that such
permissions or approvals are not required, or (iii) applicable laws, regulations, or
interpretations change and you are required to obtain such permissions or approvals in the
future.
Item 3. Key Information, D. Risk Factors, page 3
6.At the onset of your risk factor discussion, please add a risk factor that addresses your
corporate structure and being based in or having the majority of the company’s operations
in China. Discuss the risks it poses to investors. In particular, describe the significant

 FirstName LastNameWallace Lee
 Comapany NameBon Natural Life Limited
 May 1, 2023 Page 3
 FirstName LastNameWallace Lee
Bon Natural Life Limited
May 1, 2023
Page 3
regulatory, liquidity, and enforcement risks. For example, specifically discuss risks arising
from the legal system in China, including risks and uncertainties regarding the
enforcement of laws and that rules and regulations in China can change quickly with little
advance notice; and the risk that the Chinese government may intervene or influence your
operations at any time, or may exert more control over offerings conducted overseas
and/or foreign investment in China-based issuers, which could result in a material change
in your operations and/or the value of your securities. Acknowledge any risks that any
actions by the Chinese government to exert more oversight and control over offerings that
are conducted overseas and/or foreign investment in China-based issuers could
significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of your securities to significantly decline or be worthless.
Item 15. Controls and Procedures
A. Disclosure Controls and Procedures , page 102
7.Item 15(a) of Form 20-F requires you to disclose the conclusions of your principal
executive and principal financial officers, or persons performing similar functions,
regarding the effectiveness of your disclosure controls and procedures. Please note that
disclosure controls and procedures and internal control over financial reporting require
two separate and distinct assessments and conclusions.  Please amend the filing to include
management’s assessment of the effectiveness of disclosure controls and procedures as of
September 30, 2022 as required by Item 15(a) of Form 20-F.
B. Management's Annual Report on Internal Control Over Financial Reporting, page 102
8.You state this annual report does not include a report of management’s assessment
regarding internal control over financial reporting due to the transition period established
by rules of the SEC for newly public companies. However, we note that you filed an
annual report on Form 20-F for the year ended September 30, 2021 pursuant to Section
13(a) or 15(d) of the Exchange Act. Please amend your filing to include management’s
report on internal control over financial reporting for the year ended September 30, 2022.
Refer to Item 15(b) and Instruction 1 to Item 15 of Form 20-F.
Exhibits
9.Your certifications filed as Exhibit 31.1 and 31.2 appear to include modifications from the
standard language, including paragraph 4(d). In the amended filing and other future
filings, please revise these certifications to include the exact language as provided in
Exhibit Instruction 12 to Form 20-F.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameWallace Lee
 Comapany NameBon Natural Life Limited
 May 1, 2023 Page 4
 FirstName LastName
Wallace Lee
Bon Natural Life Limited
May 1, 2023
Page 4
            You may contact Gary Newberry at (202) 551-3761 or Tara Harkins, Reviewing
Accountant at (202) 551-3639 if you have questions regarding comments on the financial
statements and related matters.  Please contact Arzhang Navai at (202) 551-4676 or Joe McCann,
Legal Branch Chief, at (202) 551-6262 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
filename1.htm

VIA
EDGAR

December
2, 2022

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Division
of Corporation Finance

Washington,
D.C. 20549

    Re:
    Bon
                                            Natural Life Limited

    Amended
    Registration Statement on Form F-3

    File
    No. 333-267116

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Bon Natural Life Limited (the “Company”) hereby requests acceleration
of the effective date of its Amended Registration Statement on Form F-3 (SEC File No. 333-267116) to 9:00 a.m. Eastern Standard Time
on Wednesday, December 7, 2022, or as soon thereafter as is practicable.

The
Company acknowledges the following:

    ●
    Should
    the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission
    from taking any action with respect to the filing;

    ●
    The
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
    the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    The
    Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

Bon
Natural Life Limited

    By:
    /s/
    Yongwei Hu

    Yongwei
    Hu

    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

    Joe
    Laxague

    Partner

    jlaxague@cronelawgroup.com

    Mason
    Allen

    Of
    Counsel

    mallen@cronelawgroup.com

VIA
EDGAR

November
22, 2022

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Abby
    Adams

    Re:
    Bon
    Natural Life Limited

    Amendment
    No. 2 to Registration Statement on Form F-3

    Filed
    October 31, 2022

    File
    No. 333-267116

Dear
Ms. Adams:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities and Exchange
Commission (the “Commission”) in its letter dated November 14, 2022, commenting on the Company’s Amended Registration
Statement on Form F-3 filed October 31, 2022 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Amendment
No. 2 to Registration Statement on Form F-3

Cover
Page

1.
Revise the cover page to disclose the information set forth in the last sentence of your supplemental response to comment 1 and
cross-reference an explanation of the “Negative List.” Your disclosure should address how your operations fall outside
of the categories covered by the most recent edition of the Negative List, and any relevant guidelines or provisions that informed
your determination that the prohibition under the Negative List does not apply to your operations.

Response:
In response to this comment, the Company has amended the Registration Statement to include the information requested, to include a brief
explanation of why its business is not included in the most recent version of the Negative List, and to include a cross-reference to
the explanation of the Negative List included in its most recent annual report on Form 20-F.

Abby
Adams

United
States Securities and Exchange Commission

November
22, 2022

Page
2 of 2

2.
We acknowledge your response to prior comment 3. However, we note that the crossreference remains in brackets and it is unclear how
the referenced disclosure in the Form 20-F relates to the prospectus disclosure in the document regarding the intercompany transfer.
Please revise accordingly.

Response:
In response to this comment, the Company has amended the Registration Statement to clarify the reference and add additional specificity.
The brackets, which were intended as parentheticals, have been removed.

Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.

THE
CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
November 14, 2022
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
25F, Rongcheng Yungu, Keji 3rd Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Amendment No. 2 to Registration Statement on Form F-3
Filed October 31, 2022
File No. 333-267116
Dear Yongwei Hu:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 18, 2022 letter.
Amendment No. 2 to Registration Statement on Form F-3
Cover Page
1.Revise the cover page to disclose the information set forth in the last sentence of your
supplemental response to comment 1 and cross-reference an explanation of the "Negative
List."  Your disclosure should address how your operations fall outside of the categories
covered by the most recent edition of the Negative List, and any relevant guidelines or
provisions that informed your determination that the prohibition under the Negative List
does not apply to your operations.
2.We acknowledge your response to prior comment 3.  However, we note that the cross-
reference remains in brackets and it is unclear how the referenced disclosure in the Form
20-F relates to the prospectus disclosure in the document regarding the intercompany

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 November 14, 2022 Page 2
 FirstName LastName
Yongwei Hu
Bon Natural Life Limited
November 14, 2022
Page 2
transfer. Please revise accordingly.
            Please contact Abby Adams at 202-551-6902 or Dorrie Yale at 202-551-8776 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

VIA
EDGAR

October
31, 2022

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Abby
    Adams

    Re:
    Bon
    Natural Life Limited

    Amendment
    No. 1 to Registration Statement on Form F-3

    Filed
    October 3, 2022

    File
    No. 333-267116

Dear
Ms. Adams:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities and Exchange
Commission (the “Commission”) in its letter dated October 18, 2022, commenting on the Company’s Amended Registration
Statement on Form F-3 filed October 3, 2022 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Amendment
No. 1 to Registration Statement on Form F-3

Cover
Page

1.
We note your response to comment 1 and the first paragraph of added disclosure on the cover page wherein you state, “Although we
own and control our PRC operating subsidiaries, investors in this offering may never hold equity interests directly in our operating
entities.” Revise to clarify that the entity selling shares in this offering, the Cayman Islands entity, cannot and does not hold
equity interests directly in the operating entities, but through your Hong Kong and Chinese subsidiaries, as shown in the organization
chart. Also, please revise the sentence beginning: “Because all of our business operations are conducted in China through our wholly-owned
subsidiaries, the Chinese government may intervene or influence the operation of our PRC operating entities . . .” to clarify cause
and effect. Revise to clarify, if true, that the reason this structure is used is to provide investors with exposure to foreign investment
in China based companies where Chinese law prohibits direct foreign investment in the operating companies, and disclose that investors
may never hold equity interests in the Chinese operating company. Finally, please provide a cross-reference to your detailed discussion
of risks facing the company and the offering as a result of this structure.

Response:
In response to this comment, the Company has amended the Registration Statement to make clear that the Company does not directly own
its operating subsidiaries, but instead controls them through its Hong Kong and PRC subsidiaries as shown in the organization chart.
In addition, a cross reference to the pertinent risk factors in the Prospectus has been added after the paragraph that begins: “Because
all of our business operations are conducted in China though our wholly-owned subsidiaries, the Chinese government may intervene or influence
the operation of our PRC operating entities . . .”

    Abby Adams

United States Securities and Exchange Commission

October
                                            31, 2022

Page 2 of 3

We
respectfully advise the commission that the Company’s current structure is not designed to address any prohibitions on direct foreign
investment under Chinese law. The Company currently does not engage in any businesses where foreign investment is restricted under Chinese
law, as the Company does not participate in any sector or industry that is “restricted” or “prohibited” from
foreign investment under the “Negative List” published by China’s National Development and Reform Commission and the
Ministry of Commerce.

2.
We reissue comment 2 in part. Please revise the cover page to address whether and how the Holding Foreign Companies Accountable Act,
and related regulations will affect your company, including the Accelerating Holding Foreign Companies Accountable Act, and include a
cross-reference to a risk factor addressing those risks.

Response:
In response to this comment, the Company has amended the Registration Statement to enlarge its summary of the HFCAA and to include a
discussion of AHFCAA in that cover page summary. The risk factor discussing the HFCAA (and the AHFCAA), entitled “Although the
audit report included in this prospectus was issued by U.S. auditors who are currently inspected by the PCAOB, if it is later determined
that the PCAOB is unable to inspect or investigate our auditor completely, investors would be deprived of the benefits of such inspection
and our ordinary shares may be delisted or prohibited from trading,” remains in the Prospectus and the cross-reference to this
risk factor remains in cover page. As discussed in these disclosures, the HFCAA currently has no actual effect on the Company in that
it has never retained a non-U.S.-based auditor and has no intention to do so. The prospective and potential risks that could arise under
the HFCAA (i.e., should the Company retain a China-based auditor and/or should the PCAOB determine that it is unable to fully inspect
the Company’s auditor) are discussed in full.

3.
We acknowledge your revised disclosures in response to comment 4. Please ensure that your cross-reference to the financial statements
is correct.

Response:
The Company’s accountant has confirmed the cross-reference to the financial statements on this matter is correct.

Prospectus
Summary, page 1

4.
We reissue comment 7 in part. Please revise the summary to disclose the uncertainties regarding the status of the rights of the Cayman
Islands holding company and the challenges the company may face due to legal uncertainties and jurisdictional limits.

Response:
In response to this comment, the Company has amended the Registration Statement to add material below the corporate organizational chart
that summarizes the difficulties in effecting service of process and/or enforcing foreign judgments in China, with a reference to the
pertinent risk factor.

    Abby Adams

United States Securities and Exchange Commission

October
                                            31, 2022

Page 3 of 3

Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.

    THE
    CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
October 18, 2022
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
25F, Rongcheng Yungu, Keji 3rd Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Amendment No. 1 to Registration Statement on Form F-3
Filed October 3, 2022
File No. 333-267116
Dear Yongwei Hu:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 9, 2022 letter.
Amendment No. 1 to Registration Statement on Form F-3
Cover Page
1.We note your response to comment 1 and the first paragraph of added disclosure on the
cover page wherein you state, "Although we own and control our PRC operating
subsidiaries, investors in this offering may never hold equity interests directly in our
operating entities."  Revise to clarify that the entity selling shares in this offering, the
Cayman Islands entity, cannot and does not hold equity interests directly in the operating
entities, but through your Hong Kong and Chinese subsidiaries, as shown in the
organization chart.  Also, please revise the sentence beginning:  "Because all of our
business operations are conducted in China through our wholly-owned subsidiaries, the
Chinese government may intervene or influence the operation of our PRC operating

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 October 18, 2022 Page 2
 FirstName LastName
Yongwei Hu
Bon Natural Life Limited
October 18, 2022
Page 2
entities . . ." to clarify cause and effect.  Revise to clarify, if true, that the reason
this structure is used is to provide investors with exposure to foreign investment in China-
based companies where Chinese law prohibits direct foreign investment in the operating
companies, and disclose that investors may never hold equity interests in the Chinese
operating company.  Finally, please provide a cross-reference to your detailed discussion
of risks facing the company and the offering as a result of this structure.
2.We reissue comment 2 in part.  Please revise the cover page to address whether and how
the Holding Foreign Companies Accountable Act, and related regulations will affect your
company, including the Accelerating Holding Foreign Companies Accountable Act, and
include a cross-reference to a risk factor addressing those risks.
3.We acknowledge your revised disclosures in response to comment 4. Please ensure that
your cross-reference to the financial statements is correct.
Prospectus Summary, page 1
4.We reissue comment 7 in part.  Please revise the summary to disclose the uncertainties
regarding the status of the rights of the Cayman Islands holding company and the
challenges the company may face due to legal uncertainties and jurisdictional limits.
            Please contact Abby Adams at 202-551-6902 or Dorrie Yale at 202-551-8776 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

    Joe
    Laxague

    Partner

    jlaxague@cronelawgroup.com

    Mason
    Allen

    Of
    Counsel

    mallen@cronelawgroup.com

VIA
EDGAR

 October
03,  2022

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Abby
    Adams

    Re:
    Bon
    Natural Life Limited

    Registration
    Statement on Form F-3

    Filed
    August 26, 2022

    File
    No. 333-267116

Dear
Ms. Adams:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities and Exchange
Commission (the “Commission”) in its letter dated September 9, 2022, commenting on the Company’s Registration Statement
on Form F-3 filed August 26, 2022 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Registration
Statement on Form F-3

Cover
Page

1. Please
disclose prominently on the prospectus cover page that you are not a Chinese operating company but a Cayman Islands holding company with
operations conducted by your Chinese subsidiaries and through wholly foreign-owned enterprises (WFOEs) engaged in a joint venture based
in China and that this structure involves unique risks to investors. If true, disclose that these arrangements have not been tested in
court. Explain whether this structure is used to provide investors with exposure to foreign investment in China-based companies where
Chinese law prohibits direct foreign investment in the operating companies, and disclose that investors may never hold equity interests
in the Chinese operating company. Your disclosure should acknowledge that Chinese regulatory authorities could disallow this structure,
which would likely result in a material change in your operations and/or a material change in the value of the securities you are registering
for sale, including that it could cause the value of such securities to significantly decline or become worthless. Provide a cross-reference
to your detailed discussion of risks facing the company and the offering as a result of this structure.

Response:
We respectfully note that the Company’s corporate structure does not involve any joint venture arrangements, VIE structures, or
other arrangements designed to address any prohibitions on direct foreign investment. The Company’s corporate structure instead
consists of basic parent-subsidiary relationships based on direct vertical corporate equity ownership. In response to this comment, the
Company has amended the Registration Statement to make clear that the issuer is a Cayman Islands holding company and that investors in
the offering will never hold equity interests directly in the Company’s various operating subsidiaries. In addition, disclosures
regarding the risks of potential future regulatory action by China’s CAC and CRSC have been added to the cover page.

Abby
Adams

United
States Securities and Exchange Commission

 October
03,  2022

Page
2 of 6

2. Provide
prominent disclosure about the legal and operational risks associated with being based in or having the majority of the company’s
operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or
the value of the securities you are registering for sale or could significantly limit or completely hinder your ability to offer or continue
to offer securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should
address how recent statements and regulatory actions by China’s government, such as those related to the use of variable interest
entities and data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business, accept
foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether your auditor is subject to the determinations
announced by the PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies Accountable Act and related regulations
will affect your company. Your prospectus summary should address, but not necessarily be limited to, the risks highlighted on the prospectus
cover page.

Response:
We respectfully note that the Company does not make use of variable interest entity structures. In response to this comment, the Company
has added additional disclosures addressing the matters discussed in this comment to the prospectus cover page in bold text.

3. Clearly
disclose how you will refer to the holding company, subsidiaries, and VIEs when providing the disclosure throughout the document so that
it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations.
For example, disclose, if true, that your subsidiaries conduct operations in China, and that the holding company does not conduct operations.
Disclose clearly the entity (including the domicile) in which investors are purchasing an interest..

Response:
We respectfully note that the Company does not make use of variable interest entity structures. In response to this comment, the Company
has amended the Registration Statement to add the following additional text below the chart detailing the entities in its corporate family:
“All of our actual business operations are conducted through Xi’an App-Chem and its subsidiaries. Bon Natural Life Limited
(the Cayman Islands holding company offering securities through this Prospectus), its immediate Hong Kong subsidiary Tea Essence, and
Tea Essence’s subsidiaries Xi’an CMIT and Xi’an Youpincui, function solely as holding companies.” Further, the
Company has amended the Registration Statement so that its top operating subsidiary, Xi’an App- Chem, is referred to in the third
person when discussing actual business operations, while the conventional first person plural usage is retained when discussing the offering,
regulatory matters, and other items pertinent to the enterprise as a whole.

Abby
Adams

United
States Securities and Exchange Commission

 October
03,  2022

Page
3 of 6

4. Provide
a description of how cash is transferred through your organization and disclose your intentions to distribute earnings. State whether
any transfers, dividends, or distributions have been made to date between the holding company, its subsidiaries, or to investors, and
quantify the amounts where applicable. Provide a cross-reference to the consolidated financial statements.

Response:
In response to this comment, the Company has amended the Registration Statement to provide the description requested, including a reference
to the Company’s financial statements for the inter-company transfer discussed in these additional disclosures. This disclosure,
which was originally included under the subsection entitled “History and Development of the Company,” has been reproduced
on the cover page in bold text.

5. Disclose
on the cover page how any regulatory actions related to data security or antimonopoly concerns in Hong Kong or Macau have or may impact
the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or foreign exchange.

Response:
As the Company’s Hong Kong subsidiary serves solely as an intermediate holding company, and with all operations being conducted
in mainland China, the Company does not believe that such regulatory actions particular to Hong Kong, if any, will affect the Company
separately or differently from those already applicable (or potentially applicable in the future) in mainland China.

Commonly
Used Defined Terms, page iii

6. We
refer to your definition of “China,” and the “PRC,” which exclude Hong Kong and Macau. Please revise your disclosures
as appropriate to (1) clarify that legal and operational risks associated with operating in China also apply to any of your operations
in Hong Kong or Macau, (2) discuss the commensurate laws and regulations in Hong Kong (and Macau, if applicable to you), and (3) address
throughout your filing the applicable legal and regulatory risks and consequences associated with those laws and regulations. As an example
only, please expand your disclosure under the heading “Enforceability of Civil Liabilities” to address risks related to the
enforceability of judgments in Hong Kong.

Response:
In response to this comment, the Company has amended the Registration Statement to include Hong Kong and Macau in the definition of “China.”
As discussed above, regulations particular to these Chinese dependencies do not present the Company with separate or different regulatory
risks from those already applicable in mainland China.

Prospectus
Summary, page 1

7. Please
revise the diagram of the company’s corporate structure to identify clearly the entity in which investors are purchasing their
interest and the entity(ies) in which the company’s operations are conducted. Revise the diagram and the associated table to indicate
who owns the remaining percentages of the entities in the diagram, such as Xi’an Dietary and Tianjin YHX. Move the dotted line
in the graph so that it appears above the Hong Kong entity, or advise. Revise the font of the diagram so that both the letters and numbers
are large enough to be legible. Disclose the uncertainties regarding the status of the rights of the Cayman Islands holding company and
the challenges the company may face due to legal uncertainties and jurisdictional limits.

Response:
In response to this comment, the Company has amended the Registration Statement to replace the corporate diagram with one addressing
the concerns in this comment.

Abby
Adams

United
States Securities and Exchange Commission

 October
03,  2022

Page
4 of 6

8. Add
a summary of risk factors to the prospectus summary, and in that section, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China pose to investors. In particular, describe the significant
regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the prospectus or
incorporated by reference. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties
regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk
that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted
overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value
of the securities you are registering for sale. Acknowledge any risks that any actions by the Chinese government to exert more oversight
and control over offerings that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly
decline or be worthless.

Response:
In response to this comment, the Company has amended the Registration Statement to add a summary of Significant Risk Factors and to also
add some additional Risk Factors reflecting the concerns outlined in this comment.

9. Disclose
each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions requirements
from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that
is required to approve your operations, and state affirmatively whether you have received all requisite permissions or approvals and
whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you or your
subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals
are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or
approvals in the future.

Response:
In response to this comment, the Company has amended the Registration Statement to further clarify that, at the present time, the Company
and its subsidiaries, (1) are not required to obtain permissions or approvals from any PRC authorities to operate or issue its Ordinary
Shares to foreign investors; and (2) are not subject to permission requirements from the China Securities Regulatory Commission (the
“CSRC”), the Cyberspace Administration of China (the “CAC”) or any other entity that is required to approve of
its operations. The consequences of a mistaken conclusion in this regard, or of being subjected to new approval requirements in the future,
which were orignally disclosed in the Risk Factor entitled “If the Chinese government were to impose new requirements . . .”,
have been reiterated in the Prospectus Summary.

Abby
Adams

United
States Securities and Exchange Commission

 October
03,  2022

Page
5 of 6

10. Disclose
that trading in your securities may be prohibited under the Holding Foreign Companies Accountable Act if the PCAOB determines that it
cannot inspect or investigate completely your auditor, and that as a result an exchange may determine to delist your securities. Disclose
whether your auditor is subject to the determinations announced by the PCAOB on December 16, 2021.

Response:
In response to this comment, the Company has amended the Registration Statement to add a risk factor and other disclosures regarding
the HFCAA and related issues.

11. Revise
to provide a summary risk factor addressing the difficulty transferring cash from China.

Response:
In response to this comment, the Company has amended the Registration Statement to add an additional risk factor on this issue.

Risk
Factors, page 13

12. Given
the Chinese government’s significant oversight and discretion over the conduct of your business, please revise to highlight separately
the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material change
in your operations and/or the value of the securities you are registering.

Response:
In response to this comment, the Company has amended the Registration Statement to add an additional risk factor on this issue.

13. In
light of recent events indicating greater oversight by the Cyberspace Administration of China (CAC) over data security, particularly
for companies seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight impacts your business
and your offering and to what extent you believe that you are compliant with the regulations or policies that have been issued by the
CAC to date. We note the disclosure on pages 9 and 13 regarding “ the Measures for Cybersecurity Review (2021 version) was promulgated
and will become effective on February 15, 2022.” As that date has passed, please revise your disclosure. Also, clarify the import
of the disclosure on page 13 of your most recent Form 20-F that your leased properties have not been properly registered by the lessors
in relation to this disclosure.

Response:
The matters relating to the CAC and the Measures for Cybersecurity Review discussed in this comment were addressed in the Risk Factor
entitled “If the Chinese government chooses to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers, such action could significantly limit or completely hinder our ability to offer or continue
to offer securities to investors and cause the value of su

United States securities and exchange commission logo
September 9, 2022
Yongwei Hu
Chief Executive Officer
Bon Natural Life Limited
25F, Rongcheng Yungu, Keji 3rd Road
Xi’an Hi-tech Zone, Xi’an, China
Re:Bon Natural Life Limited
Registration Statement on Form F-3
Filed August 26, 2022
File No. 333-267116
Dear Mr. Hu:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-3
Cover Page
1.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Cayman Islands holding company with operations conducted by
your Chinese subsidiaries and through wholly foreign-owned enterprises (WFOEs)
engaged in a joint venture based in China and that this structure involves unique risks to
investors. If true, disclose that these arrangements have not been tested in court. Explain
whether this structure is used to provide investors with exposure to foreign investment in
China-based companies where Chinese law prohibits direct foreign investment in the
operating companies, and disclose that investors may never hold equity interests in the
Chinese operating company. Your disclosure should acknowledge that Chinese regulatory
authorities could disallow this structure, which would likely result in a material change in

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 September 9, 2022 Page 2
 FirstName LastNameYongwei Hu
Bon Natural Life Limited
September 9, 2022
Page 2
your operations and/or a material change in the value of the securities you are registering
for sale, including that it could cause the value of such securities to significantly decline
or become worthless. Provide a cross-reference to your detailed discussion of risks facing
the company and the offering as a result of this structure.
2.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China. Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of the securities you are registering for sale or could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless. Your disclosure
should address how recent statements and regulatory actions by China’s government, such
as those related to the use of variable interest entities and data security or anti-monopoly
concerns, have or may impact the company’s ability to conduct its business, accept
foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether
your auditor is subject to the determinations announced by the PCAOB on December 16,
2021 and whether and how the Holding Foreign Companies Accountable Act and related
regulations will affect your company. Your prospectus summary should address, but not
necessarily be limited to, the risks highlighted on the prospectus cover page.
3.Clearly disclose how you will refer to the holding company, subsidiaries, and VIEs when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations. For example, disclose, if true, that your subsidiaries conduct
operations in China, and that the holding company does not conduct operations. Disclose
clearly the entity (including the domicile) in which investors are purchasing an interest.
4.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings. State whether any transfers, dividends, or
distributions have been made to date between the holding company, its subsidiaries, or to
investors, and quantify the amounts where applicable. Provide a cross-reference to the
consolidated financial statements.
5.Disclose on the cover page how any regulatory actions related to data security or anti-
monopoly concerns in Hong Kong or Macau have or may impact the company’s ability to
conduct its business, accept foreign investments, or list on a U.S. or foreign exchange.
Commonly Used Defined Terms, page iii
6.We refer to your definition of "China," and the "PRC," which exclude Hong Kong and
Macau. Please revise your disclosures as appropriate  to (1) clarify that legal and
operational risks associated with operating in China also apply to any of your operations
in Hong Kong or Macau, (2) discuss the commensurate laws and regulations in Hong
Kong (and Macau, if applicable to you), and (3) address throughout your filing the
applicable legal and regulatory risks and consequences associated with those laws and

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 September 9, 2022 Page 3
 FirstName LastNameYongwei Hu
Bon Natural Life Limited
September 9, 2022
Page 3
regulations. As an example only, please expand your disclosure under the heading
"Enforceability of Civil Liabilities" to address risks related to the enforceability of
judgments in Hong Kong.
Prospectus Summary, page 1
7.Please revise the diagram of the company’s corporate structure to identify clearly the
entity in which investors are purchasing their interest and the entity(ies) in which the
company’s operations are conducted.  Revise the diagram and the associated table to
indicate who owns the remaining percentages of the entities in the diagram, such as Xi'an
Dietary and Tianjin YHX.  Move the dotted line in the graph so that it appears above the
Hong Kong entity, or advise. Revise the font of the diagram so that both the letters and
numbers are large enough to be legible.  Disclose the uncertainties regarding the status of
the rights of the Cayman Islands holding company and the challenges the company may
face due to legal uncertainties and jurisdictional limits.
8.Add a summary of risk factors to the prospectus summary, and in that section, disclose the
risks that your corporate structure and being based in or having the majority of the
company’s operations in China pose to investors. In particular, describe the significant
regulatory, liquidity, and enforcement risks with cross-references to the more detailed
discussion of these risks in the prospectus or incorporated by reference. For example,
specifically discuss risks arising from the legal system in China, including risks and
uncertainties regarding the enforcement of laws and that rules and regulations in China
can change quickly with little advance notice; and the risk that the Chinese government
may intervene or influence your operations at any time, or may exert more control over
offerings conducted overseas and/or foreign investment in China-based issuers, which
could result in a material change in your operations and/or the value of the securities you
are registering for sale. Acknowledge any risks that any actions by the Chinese
government to exert more oversight and control over offerings that are conducted overseas
and/or foreign investment in China-based issuers could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value
of such securities to significantly decline or be worthless.
9.Disclose each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business and to offer the securities being
registered to foreign investors. State whether you or your subsidiaries are covered by
permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve your operations, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been
denied. Please also describe the consequences to you and your investors if you or your
subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and you are required to obtain such

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 September 9, 2022 Page 4
 FirstName LastNameYongwei Hu
Bon Natural Life Limited
September 9, 2022
Page 4
permissions or approvals in the future.
10.Disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or investigate
completely your auditor, and that as a result an exchange may determine to delist your
securities. Disclose whether your auditor is subject to the determinations announced by
the PCAOB on December 16, 2021.
11.Revise to provide a summary risk factor addressing the difficulty transferring cash from
China.
Risk Factors, page 13
12.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to highlight separately the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of the securities you are registering.
13.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your offering and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.  We note the disclosure
on pages 9 and 13 regarding " the Measures for Cybersecurity Review (2021 version) was
promulgated and will become effective on February 15, 2022."  As that date has passed,
please revise your disclosure.  Also, clarify the import of the disclosure on page 13 of
your most recent Form 20-F that your leased properties have not been properly registered
by the lessors in relation to this disclosure.
14.Expand your risk factor disclosure to explain whether there are any commensurate laws or
regulations in Hong Kong or Macau which result in oversight over data security and
explain how this oversight impacts your business and the offering and to what extent
you believe that you are compliant with the regulations or policies that have been issued.
General
15.Please update your discussion of the Holding Foreign Companies Accountable
Act by disclosing that on August 26, 2022, the Public Company Accounting Oversight
Board (PCAOB) signed a Statement of Protocol with the China Securities Regulatory
Commission and the Ministry of Finance of the People's Republic of China, taking the
first step toward opening access for the PCAOB to inspect and investigate registered
public accounting firms headquartered in mainland China and Hong Kong.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Limited
 September 9, 2022 Page 5
 FirstName LastName
Yongwei Hu
Bon Natural Life Limited
September 9, 2022
Page 5
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Abby Adams at 202-551-6902 or Dorrie Yale at 202-551-8776 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

June
21, 2021

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

Office
of Life Sciences

100
F St., NE

Washington,
D.C. 20549

    Re:
    Bon
    Natural Life Limited

    Registration
    Statement on Form F-1 (File No. 333-251182)

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933,
as amended, the undersigned, as representatives of the underwriters, hereby request acceleration of the effective date of the
above-referenced Registration Statement so that it will become effective at 5:00 p.m. Eastern Time on Wednesday, June 23, 2021,
or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

Each
of the undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed
by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange
Act of 1934, as amended, in connection with the above-referenced issue.

    Very truly yours,

    US TIGER SECURITIES, INC.

    By:
    /s/
    Dajiang Guo

    Name:
    Dajiang Guo

    Title:
    Managing Director

    NEWBRIDGE SECURITIES CORPORATION

    By:
    /s/
    Robert Abrams

    Name:
    Robert Abrams

    Title:
    General Counsel & Chief Compliance Officer

    R. F. LAFFERTY & CO., INC.

    By:
    /s/ Robert Hackel

    Name:
    Robert
    Hackel

    Title:
    Chief
    Operating Officer

CORRESP
1
filename1.htm

VIA
EDGAR

June
21, 2021

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Division
of Corporation Finance

Washington,
D.C. 20549

    Re:

                                         Bon Natural Life Limited

        Amended
        Registration Statement on Form F-1

        File
        No. 333-251182

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Bon Natural Life Limited (the “Company”) hereby requests
acceleration of the effective date of its Amended Registration Statement on Form F-1 to 5:00 p.m. Eastern Daylight Time on June
23, 2021, or as soon thereafter as is practicable.

The
Company acknowledges the following:

    ●
    Should
    the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the
    Commission from taking any action with respect to the filing;

    ●
    The
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
    relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    The
    Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the
    Commission or any person under the federal securities laws of the United States.

Bon
Natural Life Limited

    By:
    /s/
    Yongwei Hu

    Yongwei
    Hu

    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

VIA
EDGAR

March
30, 2021

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Deanna
    Virginio

    Re:
    Bon
        Natural Life Limited

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

        Filed
        January 7, 2021

        File
        No. 333-251182

Dear
Ms. Virginio:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities
and Exchange Commission (the “Commission”) in its letter dated January 21, 2021, commenting on the Company’s
Amended Registration Statement on Form F-1 filed January 7, 2021 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Registration
Statement on Form F-1 filed January 7, 2021

Compensation,
page 96

    1.
    Please
    update your compensation disclosure to reflect compensation paid during the fiscal year ended September 30, 2020. Refer to
    Item 6.B. of Form 20-F.

Response:
In response to this comment, the Registration Statement has been amended where indicated to reflect compensation paid during the
fiscal year ended September 30, 2021.

    2.
    Please
    update the financial statements included in the filing, in accordance with Item 8 of Form 20-F.

Response:
In response to this comment, the Registration Statement has been amended to include the Company’s audited financial statements
for the year ended September 30, 2021. Corresponding updates to the Company’s other disclosures, reflecting updated financial
information, have been made throughout the Registration Statement,

Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.

    THE
    CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
January 21, 2021
Yongwei Hu
Chairman and Chief Executive Officer
Bon Natural Life Ltd
C601 Gazelle Valley No. 69 Jinye Road
Xi'an Hi-Tech Zone
Xi'an China
Re:Bon Natural Life Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed January 7, 2021
File No. 333-251182
Dear Mr. Hu:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our December 30, 2020 letter.
Registration Statement on Form F-1 filed January 7, 2021
Compensation, page 96
1.Please update your compensation disclosure to reflect compensation paid during the fiscal
year ended September 30, 2020. Refer to Item 6.B. of Form 20-F.
General
2.Please update the financial statements included in the filing, in accordance with Item 8 of
Form 20-F.
            You may contact Christine Torney at 202-551-3652 or Daniel Gordon at 202-551-3486 if

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 January 21, 2021 Page 2
 FirstName LastName
Yongwei Hu
Bon Natural Life Ltd
January 21, 2021
Page 2
you have questions regarding comments on the financial statements and related matters. Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

VIA
EDGAR

January
7, 2021

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Deanna
    Virginio

    Re:
    Bon
                                         Natural Life Limited

        Registration
        Statement on Form F-1

        Filed
        December 7, 2020

        File
        No. 333-251182

Dear
Ms. Virginio:

We
write on behalf of Bon Natural Life Limited (the “Company”) in response to comments by the United States Securities
and Exchange Commission (the “Commission”) in its letter dated December 30, 2020, commenting on the Company’s
Registration Statement on Form F-1 filed December 7, 2020 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Regulations
on Production and Sale of Food Products, page 85

1.
We note your revised disclosure on page 85 in response to prior comment 2. Please revise to remove statements that “Silymarin
is safe in humans,” that “Applephenon® is safe and non toxic” and that “Stachyose is a safe ordinary
food.” Only a government agency with the requisite authority can make conclusive determinations about safety.

Response:
In response to this comment, the Registration Statement has been amended on page 85 where indicated to remove these statements.

Please
feel free to contact me should you require additional information at (775) 234-5221 or jlaxague@cronelawgroup.com.

    THE CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
December 30, 2020
Yongwei Hu
Chairman and Chief Executive Officer
Bon Natural Life Ltd
C601 Gazelle Valley No. 69 Jinye Road
Xi'an Hi-Tech Zone
Xi'an China
Re:Bon Natural Life Ltd
Registration Statement on Form F-1
Filed December 7, 2020
File No. 333-251182
Dear Mr. Hu:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Regulations on Production and Sale of Food Products, page 85
1.We note your revised disclosure on page 85 in response to prior comment 2. Please revise
to remove statements that "Silymarin is safe in humans," that "Applephenon® is safe and
non toxic" and that "Stachyose is a safe ordinary food." Only a government agency with
the requisite authority can make conclusive determinations about safety.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 December 30, 2020 Page 2
 FirstName LastName
Yongwei Hu
Bon Natural Life Ltd
December 30, 2020
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Christine Torney at 202-551-3652 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters. Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

United States securities and exchange commission logo
October 5, 2020
Yongwei Hu
Chairman and Chief Executive Officer
Bon Natural Life Ltd
C601 Gazelle Valley No. 69 Jinye Road
Xi'an Hi-Tech Zone
Xi'an China
Re:Bon Natural Life Ltd
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted September 21, 2020
CIK No. 0001816815
Dear Mr. Hu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted September 21, 2020
Risk Factors , page 12
1.We note your expanded disclosure in response to comment 18.  Please also include risk
factor disclosure indicating that you are dependent on patents held by Xi'an App-Chem.
The discussion should address the potential consequences if;
•the PRC government finds that your agreements establishing your structure do not
comply with PRC laws; or
•Xi'an App-Chem breaches your contractual arrangements or refuses to renew them.

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 October 5, 2020 Page 2
 FirstName LastName
Yongwei Hu
Bon Natural Life Ltd
October 5, 2020
Page 2
We may incur material product liability claims, which could increase our costs and harm our
financial condition and operating results., page 19
2.We note your response to prior comment 20. Please revise your disclosure on page 19 to
remove the statement that your products are believed to be "safe." Only a government
agency with the requisite authority can make conclusive determinations about safety. In
an appropriate location in your prospectus, please also describe the objective results
observed from the studies and reports you have listed.
Regulations on Production and Sale of Food Products, page 75
3.We note your response to prior comment 22 and your additional disclosure regarding your
REACH certification and related EU regulations. Please provide similar disclosure
regarding your GRAS certification in the United States.
Financial Statements, page F-1
4.Please update the Company's financial statements in accordance with Item 8 of Form 20-
F.
            You may contact Christine Torney at 202-551-3652 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

United States securities and exchange commission logo
August 11, 2020
Yongwei Hu
Chairman and Chief Executive Officers
Bon Natural Life Ltd
C601 Gazelle Valley No. 69 Jinye Road
Xi'an Hi-Tech Zone
Xi'an China
Re:Bon Natural Life Ltd
Draft Registration Statement on Form F-1
Filed July 13, 2020
CIK No. 0001816815
Dear Mr. Hu:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 filed July 13, 2020
Cover Page, page 2
1.Please revise page 2 to include the date of the prospectus. Additionally, if you intend to
use the prospectus before the effective date of the registration statement, please include
the "subject to completion legend." Refer to Item 501(b)(9) and Item 501(b)(10).
Prospectus Summary
Our Business, page 4
2.If accurate, please clarify here, and throughout your document, that your products have
not been approved as effective in treating or preventing any health conditions and/or

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 August 11, 2020 Page 2
 FirstName LastNameYongwei Hu
Bon Natural Life Ltd
August 11, 2020
Page 2
diseases by a regulatory agency in the PRC.  Additionally, removed statements indicating
that your products manage and/or improve health.  If this is inaccurate, please identify the
agency, describe the approval process and describe any applicable clinical trials.  Please
similarly revise page 12 where you indicate your new products focus on preventing
respiratory infection and preventing memory loss.
Our Strengths, page 5
3.We note your disclosure that "Xi’an App-Chem is listed as a key enterprise with ensured
supplies in the COVID-19 prevention and control period by various Chinese government
agencies." Please revise your disclosure to clearly state that stachyose has not been proven
effective in preventing, treating, or controlling the spread of COVID-19. Additionally,
briefly describe what qualificationsfor a Company to be listed as a "key enterprise" and
the advantage to the Company of such designation.
Corporate History and Structure, page 8
4.Please disclose in this section the fact that the shareholders of your VIE may have
interests that conflict with you.
5.We note your disclosure on page 15 that "the pledged shares in Xi’an App-Chem is still
pending for registration with the local branch of the State Administration for Market
Regulation." Do you plan to complete your offering while the registration of the share
pledges is still pending, and therefore, are not yet deemed validly created. If so, please
explain these circumstances in your summary and include a risk factor discussion
clarifying the potential consequences.
Implications of Being an Emerging Growth Company, page 9
6.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.
Nutritional supplemental products maybe supported by limited availability of conclusive clinical
studies, page 12
7.We note your disclosure indicating that you believe your products are safe despite the
"little long term experience with human consumption" and your dependence on
consumers' perception of the efficacy, safety and quality of your products.   With respect
to your products that lack a long history of use, please include information about any
safety related trials you conducted, including the objective results of such trials.

Additionally, we note your reference to "limited availability of conclusive studies."  Only
a government agency with the requisite authority can make conclusive determinations
about safety and efficacy.  If your products do not have such approval, revise your

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 August 11, 2020 Page 3
 FirstName LastNameYongwei Hu
Bon Natural Life Ltd
August 11, 2020
Page 3
disclosure to clearly state your products have not been deemed safe or effective.  Your
indication that users may perceived them to be safe and effective despite the lack of
approval is not appropriate.

Risk Factors, page 12
8.Please include a separate risk factor discussion regarding the PCAOB's lack of access to
audit work papers, preventing the PCAOB from fully evaluating audits and quality control
procedures of auditors based in China.
Risks related to our corporate structure, page 15
9.Please explain your references to risks of foreign investment in telecom services in China.
It is not clear how these risks apply to yours business.
You may experience difficulties in effecting service of legal process, enforcing foreign
judgments or bringing actions in China ..., page 20
10.Please revise your statement that authorities in China "may" establish a regulatory
cooperative mechanism to implement cross border supervision and administration to
clearly state that the authorities have not established a regulatory cooperative mechanism,
leaving no mechanism to obtain information or conduct an investigation, if necessary.
We may rely on dividends and other distributions on equity paid by our PRC subsidiary..., page
21
11.Please quantify amounts currently available for dividends and quantify the current
percentage of registered capital in reserves.
Market Drivers, page 58
12.We note your statement that "According to International Monetary Fund (IMF), per capita
annual disposable income of the PRC increased with a CAGR of approximately 9.0%."
Please expand your disclosure to clarify the time period over which such growth
occurred.
Business
Overview , page 59
13.We note your disclosure that you have developed four technology platforms for "natural
product large-scale separation, natural product safety improvement, natural product
activity enhancement, and natural product function compounding." Please expand your
disclosure to provide a description of each of the four platforms and how they relate to
your product offerings.
14.We note that throughout the prospectus you refer to the "products and services" that you

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 August 11, 2020 Page 4
 FirstName LastNameYongwei Hu
Bon Natural Life Ltd
August 11, 2020
Page 4
provide. Please expand your disclosure to also include a description of the services that
you offer.
Product Categories, page 59
15. Please provide support for your statement that "[y]our ambroxide products are produced
with higher purity and yield than industry average."
16.Please expand your disclosure to explain what a bioactive food ingredient is and how each
ingredient is designed to be used. For example, on page 12, we note your disclosure
regarding the use of  "stachyose as a dietary supplement for infants."
Manufacturing , page 60
17.We note your disclosure on page 65 that "[y]our main competitors’ technologies are
mainly traditional physical and chemical techniques such as extraction and separation"
and that "[you] employ more advanced bio-manufacturing technologies." Please expand
your disclosure to explain the traditional physical and chemical manufacturing techniques
used and how the manufacturing process you've outlined uses more advanced
technologies.
Intellectual Property, page 61
18.Please revise your disclosure to state the type of patent issued (invention, utility model or
design), the expiration date of each patent and the corporate entity that holds the rights to
each patent.
Marketing and Competition, page 63
19.We note your disclosure on page 63 that your products "are quick-acting and potent, as
well as safe and compliant with local legal requirements." Please delete the statements that
the products are safe and effective unless they have been determined to be so by the
applicable government agency with requisite authority.
20.We note your disclosure on page 19 that you "rely upon published and unpublished safety
information including clinical studies on ingredients used in [y]our products."  Please
expand your disclosure to describe the referenced studies and their objective findings in
terms of clinical endpoints, as opposed to conclusions.
Property, Plants and Equipment, page 70
21.We note your disclosure on page 70 that the Weinan Raw Materials and Ingredients
Production Site is leased by you. Please file the lease agreement or explain your basis for
determining it s not required to be filed.. Please refer to Item 601(b)(10).
Regulations on Production and Sale of Food Products, page 74
22.We note your disclosure on page 63 that "[you] sell [y]our products primarily through

 FirstName LastNameYongwei Hu
 Comapany NameBon Natural Life Ltd
 August 11, 2020 Page 5
 FirstName LastName
Yongwei Hu
Bon Natural Life Ltd
August 11, 2020
Page 5
direct distributors in the PRC and, to some extent, to overseas customers in Europe."
Additionally we note your disclosure on page 55 that you have generated approximately
$5 million in revenue from overseas. To the extent applicable to your products and
services, please also describe any food safety or related regulations in other countries
where you conduct sales, such as Europe. Please also clarify which corporate entity holds
the Food Production Licenses and Food Business Licenses.
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Capital Leases Obligation, page F-13
23.Please revise disclosures to state if the Company has adopted the Accounting Standards
Codification (ASC) 842, the date of adoption, the method of adoption, how the adoption
was implemented, and the practical expedient adopted if any. Follow the guidance
provided in ASC 842-50.
Exhibit Index, page II-2
24.For each director nominee, please file the consent required by Rule 438 as an exhibit to
the registration statement.
25.We note that the labor contracts filed as exhibit 10.7 and 10.8 do not appear to
be translated in their entirety. Please refile the full English translation of each agreement.
            You may contact Christine Torney at 202-551-3652 or Daniel Gordon at 202-551-3486 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences