SecProbe.io

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 HUHUTECH INTERNATIONAL GROUP INC.

 December 16, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, NE

 Washington, D.C., 20549

 Re:
 HUHUTECH International Group Inc.

 Registration Statement on Form F-3

 File No. 333-291647

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, HUHUTECH International Group Inc. hereby requests
acceleration of the effectiveness of the above-referenced Registration Statement on Form F-3 so that such Registration Statement will
become effective at 4:00 p.m., Eastern Time, on December 18, 2025, or as soon thereafter as practicable.

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

 Very truly yours,

 HUHUTECH International Group Inc.

 By:
 /s/ Yujun Xiao

 Name:
 Yujun Xiao

 Title:
 Chief Executive Officer

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VIA EDGAR

September 26, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    File No. 333-270958

    Registration Statement on Form F-1 as amended

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, Craft Capital
Management LLC, as representative of the underwriters, hereby joins HUHUTECH International Group Inc. in requesting 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 September
30, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 under
the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated September 9,
2024, to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary
prospectus.

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,

    Craft Capital Management LLC

    By:
    /s/ Stephen Kiront

    Name:
    Stephen Kiront

    Title:
    Co-Founder and Chief Operating Officer

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HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China

September 26, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Jennifer Angelini

    Re:
    HUHUTECH International Group Inc.

    Registration Statement on Form F-1, as amended (File No. 333-270958)

    Request for Acceleration of Effectiveness

Dear Ms. Angelini:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, HUHUTECH International Group Inc. hereby requests
that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended be accelerated to and that the Registration
Statement become effective at  5:00 p.m., Eastern Time, on September 30, 2024, or as soon thereafter as practicable.

    Very truly yours,

    HUHUTECH International Group Inc.

    By:
    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

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HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

September 17, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Amendment No. 6 to Registration Statement on Form F-1

    Filed on September 9, 2024

    File No. 333-270958

Ladies and Gentlemen:

This letter is in response to the letter dated
September 13, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form
F-1 (the “Amended Registration Statement”) is being submitted to accompany this letter.

Amendment to Form F-1 filed September 9, 2024

Exhibits

 1. We
note your response to our prior comment 2, and reissue it. While a limited assumption as to bankruptcy may be appropriate in the context
of debt securities, this is overbroad with respect to a validity opinion (Cf. Sections II.B.1.e and II.B.3.a. of Staff Legal Bulletin
No. 19). Please request counsel to remove assumption 2.11 or, alternatively, to revise the opinion to indicate that any bankruptcy proceedings
would not affect the opinion set forth in paragraph 3.4 thereof.

RESPONSE: We note the Staff’s comment,
and respectfully advise that the Cayman Islands counsel has removed the assumption 2.11 and we hereby refiled Exhibit 5.1 to the Amended
Registration Statement.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

    Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

September 13, 2024
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 6 to Registration Statement on Form F-1
Filed September 9, 2024
File No. 333-270958
Dear Yujun Xiao:
            We have reviewed your registration statement and have the following comment(s).
            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.
Amendment to Form S-1 filed September 9, 2024
Exhibits
1.We note your response to our prior comment 2, and reissue it. While a limited assumption
as to bankruptcy may be appropriate in the context of debt securities, this is overbroad
with respect to a validity opinion ( Cf. Sections II.B.1.e and II.B.3.a. of Staff Legal
Bulletin No. 19). Please request counsel to remove assumption 2.11 or, alternatively, to
revise the opinion to indicate that any bankruptcy proceedings would not affect the
opinion set forth in paragraph 3.4 thereof.
            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.

September 13, 2024
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.
            Please contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Yarona L. Yieh

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HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

September 9, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Amendment No. 5 to Registration Statement on Form F-1

    Filed on August 28, 2024

    File No. 333-270958

Ladies and Gentlemen:

This letter is in response to the letter dated
September 5, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form
F-1 (the “Amended Registration Statement”) is being submitted to accompany this letter.

Amendment to Form F-1 filed August 28, 2024

General

 1. We
note that you have deleted disclosures relating to the Trial Measures filings process with the CSRC from your Summary and Risk Factors
sections. Please restore these disclosures as they existed in the previous amendment to your registration statement filed on June 21,
2024, together with updates if and as appropriate.

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have restored these disclosures as they existed in the previous amendment to the registration statement
filed on June 21, 2024.

Exhibits

    2.
    Please have counsel remove assumption 2.11 from the legal opinion filed as Exhibit 5.1 It is not appropriate for counsel to assume that the company is not in bankruptcy. For more information, refer to Section II.B.3.a. of Staff Legal Bulletin No. 19.

RESPONSE: With respect to assumption 2.11,
the Cayman Islands Counsel, Mourant Ozannes (Cayman) LLP, respectfully submits that it is necessary and should not be omitted for the
following reasons:

(i) a resolution to wind up the Company
may have been passed of which we are not aware, which this is a factual matter that we cannot independently verify;

(ii) whether or not the Company is insolvent
(but not in liquidation) is a matter of fact that we are not able to verify;

(iii) if the Company is insolvent, any
transactions entered into by it may be challenged by the liquidator (e.g., as an undervalue transaction, unfair preference, or extortionate
credit transaction);

(iv) a recent application for the Company’s
insolvent liquidation may have been filed at the Grand Court, which does not show on the Court Searches, and, if the Company is in liquidation,
its directors cease to have the power to deal with its assets or to cause it to enter into contracts; and

(v) following the commencement of a
voluntary liquidation, any transfer of shares without the sanction of the liquidator and any alteration in a company’s members is
void.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

    Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

September 5, 2024
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 5 to Registration Statement on Form F-1
Filed August 28, 2024
File No. 333-270958
Dear Yujun Xiao:
            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.
Amendment to Form F-1 filed August 28, 2024
General
1.We note that you have deleted disclosures relating to the Trial Measures filings process
with the CSRC from your Summary and Risk Factors sections. Please restore these
disclosures as they existed in the previous amendment to your registration statement filed
on June 21, 2024, together with updates if and as appropriate.
Exhibits
2.Please have counsel remove assumption 2.11 from the legal opinion filed as Exhibit 5.1 It
is not appropriate for counsel to assume that the company is not in bankruptcy. For more
information, refer to Section II.B.3.a. of Staff Legal Bulletin No. 19.

September 5, 2024
Page 2
            Please contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Yarona L. Yieh

CORRESP
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HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

June 21, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Amended Registration Statement on Form F-1

    Filed on June 3, 2024

    File No. 333-270958

Ladies and Gentlemen:

This letter is in response to the letter dated
June 17, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form
F-1 (the “Amended Registration Statement”) is being submitted to accompany this letter.

Amendment No. 3 to Form F-1 filed June 3, 2024

General

    1.
    We note your revisions in response to our prior comment 3. In some instances, it appears these revisions removed updates and
    reinstated earlier disclosure which does not reflect legislative and other developments that have occurred to date. Accordingly,
    please further revise your disclosure to reflect appropriate updates, including the following items:

 ● Your discussion of the Holding Foreign Companies Accountable
Act should reflect the amendments of the Consolidated Appropriations Act, 2023, and related regulations. Include that trading in your
securities may be prohibited under the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act,
2023, and related regulations if the PCAOB determines that it cannot inspect or investigate completely your auditor for a period of two
consecutive years, and that as a result an exchange may determine to delist your securities.

 ● Revise disclosure that refers to past events in the future
tense (for example, and without limitation, “The SEC will begin to identify and list Commission-Identified Issuers on its website
shortly after registrants begin filing their annual reports for 2021” and “The PCAOB . . . is making plans to resume regular
inspections in early 2023”).

 ● Revise
disclosure indicating that approval of the CSRC or other PRC authorities is not required (for example, on pages 15, 29, and 32) for consistency
with disclosure elsewhere indicating that you have applied for and received CSRC approval in connection with your listing.

 ● Update disclosure
                                            on page 64 regarding cash transfers between the holding company and its subsidiaries to additionally
                                            refer to the year ended December 31, 2023.

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have revised our disclosure in the Amended Registration Statement to reflect appropriate updates, including
the above-mentioned items.

    2.
    We note disclosure that your PRC subsidiaries have obtained “substantially all” permissions and approvals required for your operations. Please revise your disclosure to describe each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business. 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. Without limitation, your disclosure should specifically address the approval of the Ministry of Commerce related to the reorganization that was completed on January 14, 2022, which is referenced on page 92.

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have revised the disclosure relating to PRC subsidiaries and regulations in the Amended Registration Statement.

Signatures, page II-6

    3.
    Please revise to identify the individual(s) signing in the capacities of your principal financial officer and accounting officer or controller. Please also note that the registration statement should be signed by the majority of your board of directors. Refer to the Instructions to Signatures on Form F-1.

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have revised to identify the individual signing in the capacities of our principal financial officer and
accounting officer or controller. Also, we have revised to add the majority of our board of directors on the signature page.

Exhibits

    4.
    We note that your Management section identifies several director nominees. Please file consents for the director nominees as exhibits to your registration statement. Refer to Rule 438 of Regulation C.

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have filed consents for the director nominees as exhibits to this Amended Registration Statement.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
June 13, 2024
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 3 to Registration Statement on Form F-1
Filed June 3, 2024
File No. 333-270958
Dear Yujun Xiao:
            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 30, 2024, letter.
Amendment No. 3 to Form F-1
General
1.We note your revisions in response to our prior comment 3. In some instances, it appears
these revisions removed updates and reinstated earlier disclosure which does not reflect
legislative and other developments that have occurred to date. Accordingly, please further
revise your disclosure to reflect appropriate updates, including the following items:

•Your discussion of the Holding Foreign Companies Accountable Act should reflect
the amendments of the Consolidated Appropriations Act, 2023, and related
regulations. Include that trading in your securities may be prohibited under the
Holding Foreign Companies Accountable Act, as amended by the Consolidated

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 June 13, 2024 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
June 13, 2024
Page 2
Appropriations Act, 2023, and related regulations if the PCAOB determines that it
cannot inspect or investigate completely your auditor for a period of two consecutive
years, and that as a result an exchange may determine to delist your securities.

•Revise disclosure that refers to past events in the future tense (for example, and
without limitation, "The SEC will begin to identify and list Commission-Identified
Issuers on its website shortly after registrants begin filing their annual reports for
2021" and "The PCAOB . . . is making plans to resume regular inspections in early
2023").

•Revise disclosure indicating that approval of the CSRC or other PRC authorities is
not required (for example, on pages 15, 29, and 32) for consistency with disclosure
elsewhere indicating that you have applied for and received CSRC approval in
connection with your listing.

•Update disclosure on page 64 regarding cash transfers between the holding company
and its subsidiaries to additionally refer to the year ended December 31, 2023.
2.We note disclosure that your PRC subsidiaries have obtained "substantially all"
permissions and approvals required for your operations. Please revise your disclosure to
describe each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business. 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. Without limitation, your disclosure should
specifically address the approval of the Ministry of Commerce related to the
reorganization that was completed on January 14, 2022, which is referenced on page 92.
Signatures, page II-6
3.Please revise to identify the individual(s) signing in the capacities of your principal
financial officer and accounting officer or controller. Please also note that the registration
statement should be signed by the majority of your board of directors. Refer to the
Instructions to Signatures on Form F-1.
Exhibits
4.We note that your Management section identifies several director nominees. Please file
consents for the director nominees as exhibits to your registration statement. Refer to Rule
438 of Regulation C.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 June 13, 2024 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
June 13, 2024
Page 3
            Please contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

CORRESP
1
filename1.htm

HUHUTECH
International Group Inc.

3-1208
Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

June 3, 2024

Via
EDGAR

Division
of Corporation Finance

Office
of Manufacturing

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attention:
    Kevin
    Stertzel

    Claire
    Erlanger

    Gregory
    Herbers

    Jay
    Ingram

    Re:
    HUHUTECH
    International Group Inc.

    Amended
    Registration Statement on Form F-1

    Filed
    on January 17, 2024

    File
    No. 333-270958

Ladies
and Gentlemen:

This
letter is in response to the letter dated January 30, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) addressed to HUHUTECH International Group Inc. (the “Company,” “we,”
and “our”). For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly.
An amended Registration Statement on Form F-1 (the “Amended Registration Statement”) is being submitted to accompany this
letter.

Amendment
No. 2 to Form F-1 filed January 17, 2024

Our
Properties and Facilities, page 86

 1. Please
file as an exhibit the lease agreements for all leased properties.

RESPONSE:
We note the Staff’s comment, and respectfully advise that we have filed as exhibits the lease agreements for all leased properties
in the Amended Registration Statement.

Related
Party Transactions, page 103

    2.
    We
                                                         note your response to prior comment 2. Please file all outstanding loan agreements as exhibits to your registration statement,
                                                         including those subsequent to May 31, 2023.

RESPONSE:
We note the Staff’s comment, and respectfully advise that we have filed all outstanding loan agreements as of today as exhibits
in the Amended Registration Statement.

General

    3.
    We note the changes you made to your disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal and operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that was filed on May 31, 2023 warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value of the securities you are registering for sale. We remind you that, pursuant to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under common control with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can change quickly with little advance notice. We do not believe that your revised disclosure referencing the PRC government’s intent to strengthen its regulatory oversight conveys the same risk. Please restore your disclosures in these areas to the disclosures as they existed in the registration statement as of May 31, 2023.

RESPONSE:
We note the Staff’s comment, and respectfully advise that we have restored our disclosures in the Amended Registration Statement
in these areas to the disclosures as they existed in the registration statement as of May 31, 2023.

We
appreciate the assistance the Staff has provided with its comments. Should you have additional questions regarding the information contained
herein, please contact our securities counsel William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal
or yly@orllp.legal.

Very
truly yours,

    /s/
    Yujun Xiao

    Name:

    Yujun
    Xiao

    Title:

    Chief
    Executive Officer

United States securities and exchange commission logo
January 30, 2024
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amended Registration Statement on Form F-1
Filed on January 17, 2024
File No. 333-270958
Dear Yujun Xiao:
            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 June 8, 2023 letter.
Amendment No. 2 to Form F-1 filed January 17, 2024
Our Properties and Facilities, page 86
1.Please file as an exhibit the lease agreements for all leased properties.
Related Party Transactions, page 103
2.We note your response to prior comment 2. Please file all outstanding loan agreements as
exhibits to your registration statement, including those subsequent to May 31, 2023.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 30, 2024 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
January 30, 2024
Page 2
General
3.We note the changes you made to your disclosure appearing on the cover page, Summary
and Risk Factor sections relating to legal and operational risks associated with operating
in China and PRC regulations.  It is unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on May 31, 2023
warranting revised disclosure to mitigate the challenges you face and related disclosures.
The Sample Letters to China-Based Companies sought specific disclosure relating to the
risk that the PRC government may intervene in or influence your operations at any time,
or may exert control over operations of your business, which could result in a material
change in your operations and/or the value of the securities you are registering for sale.
We remind you that, pursuant to federal securities rules, the term “control” (including the
terms “controlling,” “controlled by,” and “under common control with”) as defined in
Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or
cause the direction of the management and policies of a person, whether through the
ownership of voting securities, by contract, or otherwise.”  The Sample Letters also
sought specific disclosures relating to uncertainties regarding the enforcement of laws and
that the rules and regulations in China can change quickly with little advance notice.  We
do not believe that your revised disclosure referencing the PRC government’s intent to
strengthen its regulatory oversight conveys the same risk.  Please restore your disclosures
in these areas to the disclosures as they existed in the registration statement as of May 31,
2023.
            Please contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

CORRESP
1
filename1.htm

HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

January 17, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Amended Registration Statement on Form F-1

    Filed on May 31, 2023

    File No. 333-270958

Ladies and Gentlemen:

This letter is in response to the letter dated June
8, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed
to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference, we have
recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form F-1
(the “Amended Registration Statement”) is being submitted to accompany this letter.

Amended Form F-1 filed May 31, 2023

Management, page 99

    1.
    Please amend your disclosure to include the annual base salary figure for CFO Huiping Zhang.

RESPONSE: We note the Staff’s
comment, and respectfully advise that we have updated our disclosure to include the annual base salary figure for CFO Huiping Zhang in
the Amended Registration Statement.

Related Party Transactions, page 102

    2.
    Please file all outstanding loan agreements as exhibits to your registration statement, including outstanding loans agreements with the Bank of China.

RESPONSE: We note the Staff’s
comment, and respectfully advise that we have filed all outstanding loan agreements as exhibits to your registration statement, including
outstanding loans agreements with the Bank of China in the Amended Registration Statement.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
June 8, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amended Registration Statement on Form F-1
Filed on May 31, 2023
File No. 333-270958
Dear Yujun Xiao:
            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 April 11, 2023 letter.
Amended Form F-1 filed May 31, 2023
Management, page 99
1.Please amend your disclosure to include the annual base salary figure for CFO Huiping
Zhang.
Related Party Transactions, page 102
2.Please file all outstanding loan agreements as exhibits to your registration statement,
including outstanding loans agreements with the Bank of China.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 June 8, 2023 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
June 8, 2023
Page 2
            You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

CORRESP
1
filename1.htm

HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

May 31, 2023

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Registration Statement on Form F-1

    Filed on March 30, 2023

    File No. 333-270958

Ladies and Gentlemen:

This letter is in response to the letter dated
April 11, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being submitted to accompany this letter.

Registration Statement on Form F-1 filed
March 30, 2023

General

 1. Please update your audited financial information and Management Discussion and Analysis of Financial
Condition and Results of Operations in your next amendment.

RESPONSE: We note the Staff’s
comment, and respectfully advise that we have updated our financial information and Management Discussion and Analysis of Financial Condition
and Results of Operations in the Amended Registration Statement.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
April 11, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Registration Statement on Form F-1
Filed on March 30, 2023
File No. 333-270958
Dear Yujun Xiao:
            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 February 22, 2023 letter.
Form F-1 filed March 30, 2023
General
1.Please update your audited financial information and Management Discussion and
Analysis of Financial Condition and Results of Operations in your next amendment.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 April 11, 2023 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
April 11, 2023
Page 2
            You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

CORRESP
1
filename1.htm

HUHUTECH International Group Inc.

3-1208 Tiananzhihui Compound

228 Linghu Road

Xinwu District, Wuxi City, Jiangsu Province

People’s Republic of China 214135

March 29, 2023

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Kevin Stertzel

    Claire Erlanger

    Gregory Herbers

    Jay Ingram

    Re:
    HUHUTECH International Group Inc.

    Draft Registration Statement on Form F-1

    Filed on February 10, 2023

    CIK 1945415

Ladies and Gentlemen:

This letter is in response to the letter dated
February 23, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to HUHUTECH International Group Inc. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. A Registration Statement on Form F-1 (the
“Registration Statement”) is being submitted confidentially to accompany this letter.

Amendment No. 2 to Draft Registration Statement
on Form F-1 Submitted February 10, 2023

General

 1. We note recent instances of extreme stock price run-ups followed by rapid price declines and stock
price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among
companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial
price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing
in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to
your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess
the rapidly changing value of your stock.

RESPONSE: We note the Staff’s
comment, and respectfully advise that we have revised the to the Registration Statement to add a risk factor on page 44 of the prospectus
that addresses the potential for rapid and substantial price volatility and any known factors particular to our offering that may add
to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly.

Cover Page

 2. We reissue prior comment 2. Please clarify whether any dividends or distributions have been made and
if so, quantify the amount. If no dividends or distributions have been made, please revise your disclosure elsewhere in the filing, specifically
on page 5 and page 53 where you state that you "do not expect to pay cash dividends again."

RESPONSE: We note the Staff’s comment,
and respectfully advise that we have revised throughout the Registration Statement to clarify that as of the date of this prospectus,
there has not been any dividends or distributions made.

Prospectus Summary, page 1

 3. We note your response to prior comment 3. Please file the written agreements with the customers and
suppliers mentioned in this section, specifically Taiwan Semiconductor Manufacturing Co., Ltd., Yangtze Memory Technology Corp., and Changxin
Memory Technologies Inc.

RESPONSE: We note the Staff’s comment, and respectfully advise that we
have revised the disclosures on page 2 and 77 of the Registration Statement regarding our contracts with clients and suppliers in this
section to clarify that the company only has direct contractual relationship with Li Yi System Engineering (Shanghai) Limited, Hefei Lanke
Investment Co., Ltd., and Shiyuan Technology Engineering Co., Ltd., who are suppliers of Taiwan Semiconductor Manufacturing Co., Ltd.,
Yangtze Memory Technology Corp., and Changxin Memory Technologies Inc. The company does not have direct contract with Taiwan Semiconductor
Manufacturing Co., Ltd., Yangtze Memory Technology Corp., and Changxin Memory Technologies Inc.

Risk Factor

Nasdaq Approval, page 50

 4. We note your response to prior comment 5. Please revise your disclosure to add the consequences to
the offering of having your application denied to include that the offering will not be completed in the absence of Nasdaq listing approval.

RESPONSE: We note the Staff’s comment, and respectfully advise that we
have revised our disclosure on page 50 of the Registration Statement to add the consequences to the offering of having our application
denied and to include that the offering will not be completed in the absence of Nasdaq listing approval.

Management Discussion and Analysis of Financial
Condition and Results of Operations Bank Loans, page 70

 5. We note your response to prior comment 7. Please file all the outstanding loan agreements as exhibits
to your registration statement, including outstanding loans agreements with the China Construction Bank and Bank of Ningbo. In the alternative,
please explain why you are not required to do so.

RESPONSE: We note the Staff’s comment, and respectfully advise that Exhibit
10.15 of the Registration Statement (English Translation of loan Contract between the Company and China Construction bank dated November
3, 2021) is the only agreement the Company has with China Construction Bank, under which the Company was entitled to request China Construction
Bank to issue fund between November 3, 2021 and November 3, 2022 for up to RMB 3,000,000. The Company had obtained RMB 1,200,000 from
China Construction Bank on December 10, 2021, and RMB 500,000 on December 21, 2021 under the agreement filed as Exhibit 10.15. Please
refer to exhibit 10.25, a statement from the Company clarifying the loan agreement with China Construction Bank for more details.

Regarding the loan agreement between the Company and Bank of Ningbo,
Exhibit 10.9 of the Registration Statement (English Translation of Working Capital Loan Agreement between the Company and Bank of Ningbo
dated March 28, 2022) is the only agreement the Company has with Bank of Ningbo, under which the Company was entitled to request Bank
of Ningbo to issue fund between March 28, 2022 and March 28, 2023 for up to RMB 3,000,000. The Company had obtained RMB 3,000,000 from
Bank of Ningbo on April 1, 2022 under the agreement filed as Exhibit 10.9. Please refer to exhibit 10.26, a statement from the Company
clarifying the loan agreement with Bank of Ningbo for more details.

    2

Related Party Transactions, page 102

 6. We note your response to prior comment 13. Please revise this section to include transactions of all
related International parties, including agreements guaranteed by Ms. Yinglai Wang.

RESPONSE: We note the Staff’s comment, and respectfully advise that we
have updated the related party transactions section to include agreements guaranteed by Ms. Yinglai Wang on page 103-105 of the Registration
Statement.

We appreciate the assistance the Staff has provided
with its comments. Should you have additional questions regarding the information contained herein, please contact our securities counsel
William S. Rosenstadt, Esq., or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or yly@orllp.legal.

Very truly yours,

    /s/ Yujun Xiao

    Name:
    Yujun Xiao

    Title:
    Chief Executive Officer

3

United States securities and exchange commission logo
February 22, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted on February 10, 2023
CIK 1945415
Dear Yujun Xiao:
            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 January 19, 2023 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted February 10, 2023
General
1.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 February 22, 2023 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
February 22, 2023
Page 2
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
Cover Page
2.We reissue prior comment 2. Please clarify whether any dividends or distributions have
been made and if so, quantify the amount. If no dividends or distributions have been
made, please revise your disclosure elsewhere in the filing, specifically on page 5 and
page 53 where you state that you "do not expect to pay cash dividends again."
Prospectus Summary, page 1
3.We note your response to prior comment 3. Please file the written agreements with the
customers and suppliers mentioned in this section, specifically Taiwan Semiconductor
Manufacturing Co., Ltd., Yangtze Memory Technology Corp., and Changxin Memory
Technologies Inc.
Risk Factor
Nasdaq Approval, page 50
4.We note your response to prior comment 5. Please revise your disclosure to add the
consequences to the offering of having your application denied to include that the offering
will not be completed in the absence of Nasdaq listing approval.
Management Discussion and Analysis of Financial Condition and Results of Operations Bank
Loans, page 70
5.We note your response to prior comment 7. Please file all the outstanding loan agreements
as exhibits to your registration statement, including outstanding loans agreements with the
China Construction Bank and Bank of Ningbo. In the alternative, please explain why you
are not required to do so.
Related Party Transactions, page 102
6.We note your response to prior comment 13.  Please revise this section to include
transactions of all related parties, including loan agreements guaranteed by Ms. Yinglai
Wang.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 February 22, 2023 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
February 22, 2023
Page 3
            You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

United States securities and exchange commission logo
January 19, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted on January 6, 2023
CIK 1945415
Dear Yujun Xiao:
            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 November 16, 2022 letter.
Draft Registration Statement on Form F-1/A filed January 6, 2023
Cover Page
1.We note your response to prior comment 2. Please disclose how you will refer to the
holding company and each subsidiary 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.  Specifically, please
disclose how you will be referring to Wuxi Xinwu District Jianmeng Electromechanical
Technology Co., Limited, HUHU Technology Co., Ltd., and HUHUTECH(HK) Limited.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 19, 2023 Page 2
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
January 19, 2023
Page 2
2.We note your response to prior comment 4. Please clarify whether any dividends or
distributions have been made and if so, quantify the amount. If no dividends or
distributions have been made, please revise your disclosure elsewhere in the filing.
Prospectus Summary, page 1
3.We note your response to prior comment 6. Please file the written agreements with the
customers and suppliers mentioned in this section.  Additionally, please clarify the
contracting parties to these agreements in your current corporate structure.
Business Segments, page 24
4.We reissue prior comment 12. Please clarify whether you have multiple business
segments.
Risk Factor
Nasdaq Approval, page 50
5.We note your response to prior comment 15. Please revise your disclosure to add the
consequences to the offering of having your application denied.
Capitalization , page 54
6.We note your capitalization table footnote (1) continues to refer to "non-accountable
expense allowance".  As such, we re-issue our prior comment number 17 in our letter
dated, November 16, 2022.   The prior comment is provided for your convenience:  "The
footnotes to your capitalization table refer to a "non-accountable expense allowance" as a
deduction to expected offering proceeds. Please tell us and explain in your disclosure, the
nature of this adjustment."
Managements Discussion and Analysis of Financial Condition and Results of Operations
Bank Loans, page 70
7.We note your response to prior comment 25. Please file all the outstanding loan
agreements as exhibits to your registration statement. In the alternative, please explain
why you are not required to do so.
8.We reissue prior comment 26. Please discuss your bank loans as sources of liquidity.
Development Opportunities, page 79
9.We note your response to prior comment 29. Please revise to elaborate on how you
determined that these will bring development opportunities.
Business, page 85
10.We note your response to prior comment 30. We reissue our comment. Please explain
how you determined that this Sales and Marketing disclosure is consistent with the

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 January 19, 2023 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
January 19, 2023
Page 3
operating expenses discussion on page 65, which states that “[s]elling expenses primarily
consisted of salary and compensation expenses relating to our sales personnel, advertising
expenses, promotional service fees . . ."  Additionally, please explain how you determined
that this Sales and Marketing disclosure is consistent with your discussion on page 62
which states that "HUHU Japan just functions as a sales and customer service center."
Properties and Facilities, page 88
11.We note your response to prior comment 31.  Please attach all lease agreements as
exhibits to your registration statement. In the alternative, please explain why you are not
required to do so.
Regulations, page 97
12.We note your response to prior comment 32. Please clarify whether the referenced
reorganization relates to the reorganization that was completed in January 2022 or the
restructuring that was completed in March 2022 and revise the disclosures in the filing.
Related Party Transactions, page 102
13.We note your response to prior comment 40. Please revise this section to include
transactions of all related parties.
            You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Yarona L. Yieh

United States securities and exchange commission logo
November 16, 2022
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Draft Registration Statement on Form F-1
Filed on October 21, 2022
File No. 377-06419
Dear Yujun Xiao:
            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.
Draft Registration Statement on Form F-1 filed October 21, 2022
Cover Page
1.We note your disclosure that you are not a Chinese operating company but a Cayman
Islands holding company with operations conducted by one or more subsidiaries.  Provide
a cross-reference to your detailed discussion of risks facing the company and the offering
as a result of this structure.
2.Clearly disclose how you will refer to the holding company and subsidiaries 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

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 2
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 2
business operations.  For example, refrain from using terms such as “we” or “our” or “the
Company” when disclosing the entity in which investors are purchasing an interest.  In
addition, please revise throughout the filing to clarify which subsidiary is currently an
operating subsidiary and refer to your subsidiaries consistently.  If there are any other
operating subsidiaries outside of China, please revise your disclosure to provide material
information to prospective investors.
3.Please explain whether you will be a controlled company under exchange rules and, as a
result, may elect not to comply with certain corporate governance requirements.  Please
update your disclosure as appropriate.
4.We note your general disclosure regarding how cash is transferred through your
organization here and in the prospectus summary and have the following comments:
•Please revise to describe more specifically for each subsidiary.
•Please clarify whether any dividends or distributions have been made and if so,
quantify the amount.  If no dividends or distributions have been made, please revise
your disclosure elsewhere in the filing.
•Please confirm whether you and your subsidiaries do not expect to pay cash
dividends in the foreseeable future to the other subsidiaries and to investors.
•Please clarify whether any of your China-based subsidiaries have incurred debt on
their own behalf, which restrict their ability to pay dividends to HUHUTECH.
•When describing the “statutory foreign debt upper limit” elsewhere in the document,
please use consistent terminology for clarity.
Prospectus Summary, page 1
5.Please refer to the table on page 1 and explain how the information is consistent with the
table included on F-14.

6.Please clarify whether you have written agreements with the customers and suppliers
mentioned in this section.  Also, file the agreements as exhibits to your registration
statement.  In the alternative, please explain why you are not required to do so.
7.In your risk factor summary, please revise your risks related to doing business in the PRC
to include cross-references to the more detailed discussion of these risks in the filing.
8.Please revise both the risk factor summary and the risk factors section to move forward
the risks related to doing business in the PRC so that such risks are prominently disclosed
within each section in relation to other identified material risks.
9.We note your disclosure that management concluded that your internal control over
financial reporting as of December 31, 2021 was ineffective.  Consider revising your
summary risk factors to include this risk.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 3
 FirstName LastName
Yujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 3
Risk Factors
COVID-19, page 20
10.We note your COVID-19 discussion that you experienced significant business disruptions,
including production and sales activities, and that COVID-19 had a material adverse effect
on your results of operations and financial condition.  Please revise your disclosure to
describe these effects.
Risk Factors
Inflation, page 24
11.We note you identify inflation among the factors that may materially affect your results on
page 24.  If recent inflationary pressures have materially impacted your operations, please
include appropriate risk factor disclosure and revise throughout the filing.  Identify the
types of inflationary pressures you are facing, describe how your business has been
affected and the resulting impact on your financial condition and results of operation, and
identify the actions planned or taken, if any, to mitigate inflationary pressure.  Finally,
please disclose whether and how your business segment, products, lines of service,
projects, or operations are materially impacted by supply chain disruptions, especially in
light of Russia’s invasion of Ukraine.  For example, discuss whether you have or expect
to:
•suspend the production, purchase, sale or maintenance of certain items;
•experience higher costs due to constrained capacity or increased commodity prices or
challenges sourcing materials;
•experience surges or declines in consumer demand for which you are unable to
adequately adjust your supply;
•be unable to supply products at competitive prices or at all due to export restrictions,
sanctions, or the ongoing invasion; or
•be exposed to supply chain risk in light of Russia’s invasion of Ukraine and/or related
geopolitical tension or have sought to “de-globalize” your supply chain.
Explain whether and how you have undertaken efforts to mitigate the impact and where
possible quantify the impact to your business.
Risk Factors
Business segments, page 27
12.Please clarify whether you have multiple business segments.
Risk Factors
HFCAA, page 38
13.We note your disclosure about the Holding Foreign Companies Accountable Act.  Please
update to specifically reference that the United States Senate has passed the Accelerating
Holding Foreign Companies Accountable Act, which, if enacted, would reduce the time
before your securities may be prohibited from trading or delisted.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 4
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 4
Risk Factors
Shareholder noncompliance, page 38
14.Please expand your disclosure to clarify which of your shareholders are not in compliance
with PRC regulations relating to offshore investment activities by PRC residents.  If any
of these shareholders is a director or member of senior management of the company and
disclosure is required pursuant to Item 8.A.7. of Form 20-F, please update your
disclosure.  Revise your filing to discuss any current legal or administrative proceedings.
Risk Factors
Nasdaq approval, page 42
15.Please add risk factor disclosure regarding the risks that Nasdaq may not approve your
application for listing.  In this regard, we note disclosure on the prospectus cover pages
that states the offering will not be completed in the absence of Nasdaq listing approval
(i.e., “if it is not approved, we will not complete this offering”).
Use of Proceeds, page 49
16.We note your disclosure that approximately 30% of the net proceeds from the offering is
expected to be used for the acquisitions of, or investments in, or setting up enterprises
focused in the same industry in other countries.  Please clarify whether this is specific to
HUHU Japan or refer to any other current or future subsidiaries and revise throughout the
filing.  Please also describe how your disclosure complies with Item 3.C.2. and 3.C.3. of
Form 20-F.
Capitalization, page 51
17.The footnotes to your capitalization table refer to a "non-accountable expense allowance"
as a deduction to expected offering proceeds.   Please tell us and explain in your
disclosure, the nature of this adjustment.
Enforceability of Civil Liberties, page 53
18.Please revise to disclose whether your directors, officers, or senior management are
located in China or Hong Kong and, if so, state that it will be more difficult to bring
actions and enforce judgments against these individuals.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
General, page 57
19.Please refer to comment 47 below.  On page 58, please tell us how you determined to
include a reference to interim results ended March 31, 2022 without providing
corresponding interim financial statements.  Revise disclosures as appropriate.
20.Please identify any trend information that is reasonably likely to have a material effect on
your results of operation or financial condition.  By way of example only, for the current

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 5
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 5
financial year, discuss any known trends or uncertainties in average contract price and
number of contracts for your system integration projects as well as cash requirements
related to the expansion of HUHU Japan, if any.  Refer to Item 5.D. of Form 20-F.
21.Revise your disclosure to include the expected construction of a 5,000 square meter R&D
plant, as discussed the Use of Proceeds section, and management’s expectations regarding
R&D spending.
22.Please revise to include the information required by Item 11 of Form 20-F.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
System integration projects contracts, page 59
23.Please clarify whether your system integration projects are long-term contracts or short-
term contracts.  Please update your disclosure to identify actions planned or taken, if any,
to mitigate inflationary pressures from these contracts and update your risk factor
disclosure as applicable.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
State-owned companies benefit, page 60
24.We note your disclosure that you expect state-owned companies “will bring future
benefits to the Company’s operations even with lower profit margin.”  Please provide any
statistical data that you believe will enhance a reader’s understanding of this statement.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Bank loans, page 62
25.Please clarify whether you have written loan agreements with banks mentioned in this
section.  Also, file the agreements as exhibits to your registration statement.  In the
alternative, please explain why you are not required to do so.
26.Please discuss your bank loans as sources of liquidity.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Material cash requirements, page 64
27.Please revise to describe all material cash requirements, including short-term and long-
term requirements, the anticipated source of funds needed to satisfy such cash
requirements and the general purpose of such requirements.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical accounting estimates, page 65
28.Please explain how your disclosure in this section complies with Item 5.E. of Form 20-F,
including how the disclosure supplements, but does not duplicate, the description of
accounting policies in the Notes to the Financial Statements.

 FirstName LastNameYujun  Xiao
 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 6
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 6
Business
Development opportunities, page 70
29.We note your disclosure that “new production lines of domestic fabrication plants ('fabs')
will bring development opportunities for us as such new fabs may require high-purity.”
Please elaborate on how you determined that these will bring development opportunities.
Business
Marketing, page 76
30.Please explain how you determined that this Sales and Marketing disclosure is consistent
with the operating expenses discussion in on page 61, which states that “[s]elling expenses
primarily consisted of salary and compensation expenses relating to our sales personnel,
advertising expenses, promotional service fees . . ."
Business
Leases, page 79
31.Please clarify whether you have written agreements for your leases mentioned in this
section.  Also, file the agreements as exhibits to your registration statement.  In the
alternative, please explain why you are not required to do so.
Regulation, page 89
32.Please revise throughout whether you applied for approval from the Ministry of
Commerce related to the reorganization and whether approval is pending or has been
granted.  Please also clarify whether the referenced reorganization relates to the
reorganization that was completed in January 2022 or the restructuring that was completed
in March 2022 and revise the disclosures in the filing.
33.To the extent HUHU Japan conducts operations in Japan, please update this section to
describe, as an example only, regulatory permissions to conduct its business.  Refer to
Item 4.B.8. of Form 20-F.
Management, page 90
34.Please clarify who is the current chairperson of the Board and revise throughout the filing.
35.Explain whether Yujun Xiao’s business experience at Shanghai Tongcheng Enterprise
Management Co., Ltd, as described in the Related Party Transaction section, should be
disclosed in this section.
36.Please revise throughout the filing to clarify which specific provisions will apply pursuant
to your Amended and Restated Memorandum and Articles of Association, which is
expected to take effect immediately prior to the effectiveness of your registration
statement, as compared to the current Memorandum and Articles of Association.  In
addition, please file your Memorandum and Articles of Association as currently in effect

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 Comapany NameHUHUTECH International Group Inc.
 November 16, 2022 Page 7
 FirstName LastNameYujun  Xiao
HUHUTECH International Group Inc.
November 16, 2022
Page 7
as an exhibit and clarify that the Amended and Restated Memorandum and Articles of
Association will be effective in connection with the completion of this offering.
37.Please describe whether there are any arrangements or understandings with respect to
shareholders, customers, suppliers or others, pursuant to which any person referred to in
the Management section was selected as a director or member of senior management.
Refer to Item 6.A.5. of Form 20-F.
38.Please describe how your disclosure complies with Item 6.E. of Form 20-F and revise
your filing throughout to clarify.
39.Please update to include compensation information for your directors.  Refer to Item 6.B.
of Form 20-F.
Related Party Transactions, page 94
40.Please update this section to reflect the information as of the date of the document,
including any additional related parties.  By way of example only, disclose your issuance
of securities to related parties to the extent applicable.  Refer to Item 7.