SecProbe.io

CORRESP
 1
 filename1.htm

 jowell
global LTD.

 VIA EDGAR

 September 4, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:
 Kate Beukenkamp

 Re:
 Jowell Global Ltd.

 Registration Statement on Form F-3
 File No. 333-289861

 Acceleration Request

 Requested Date:
 September 8, 2025

 Requested Time:
 4:00 p.m. Eastern Time

 Dear Ms. Beukenkamp:

 Pursuant to Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Jowell Global Ltd. (the " Company ")
hereby respectfully requests the Securities and Exchange Commission (the " Commission ") to accelerate
the effective date of the above-referenced Registration Statement and declare such Registration Statement effective at the "Requested
Date" and "Requested Time" set forth above or as soon thereafter as practicable.

 In connection with the
acceleration request, the Company hereby acknowledges that:

 ● should
the Commission or the staff of the Commission, 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 the 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.

 If
you have any further comments, require any further information or if any questions should arise in connection with this submission, please
call Mr. Jeffrey Li at (703) 618-2503 at FisherBroyles, LLP.

 Very truly yours,

 Jowell Global Ltd.

 By:
 /s/ Haiting Li

 Name:
 Haiting Li

 Title:
 Chief Executive Officer and
Chairman of the Board of the Directors

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 3, 2025

Haiting Li
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District
Shanghai, China 200082

 Re: Jowell Global Ltd.
 Registration Statement on Form F-3
 Filed August 26, 2025
 File No. 333-289861
Dear Haiting Li:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Kate Beukenkamp at 202-551-3861 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Jeffrey Li, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

jowell
global LTD.

VIA EDGAR

August 29, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Jennie Beysolow

    Mara Ransom

    Re:
    Jowell Global Ltd.

    Registration Statement on Form F-3

    File No. 333-264109

 Acceleration Request

    Requested Date:
    August 31, 2022

    Requested Time:
    4:00 p.m. Eastern Time

Dear Ms. Beysolow and Ms. Ransom:

Pursuant to Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Jowell Global Ltd. (the “Company”)
hereby respectfully requests the Securities and Exchange Commission (the “Commission”) to accelerate
the effective date of the above-referenced Registration Statement and declare such Registration Statement effective at the “Requested
Date” and “Requested Time” set forth above or as soon thereafter as practicable.

In connection with the
acceleration request, the Company hereby acknowledges that:

 ● should
the Commission or the staff of the Commission, 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 the 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.

If
you have any further comments, require any further information or if any questions should arise in connection with this submission, please
call Mr. Jeffrey Li at (202) 830-5905 at FisherBroyles, LLP.

    Very truly yours,

    Jowell Global Ltd.

    By:
    /s/ Zhiwei Xu

    Name:
    Zhiwei Xu

    Title:
    Chief Executive Officer and

Chairman of the Board of the Directors

CORRESP
1
filename1.htm

jowell
global LTD.

August 12, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549-0405

    Attention:
    Jennie Beysolow

    Mara Ransom

    Re:
    Jowell Global Ltd.

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

    Filed July 27, 2022

    File No. 333-264109

Dear Ms. Beysolow and Ms. Ransom:

Jowell Global Ltd. (“JWEL” or the
“Company” and sometimes referred to as “we” or “our”) is submitting this letter and the following
information in response to a letter, dated August 11, 2022, from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-3
(the “Registration Statement”) filed with the Commission on April 4, 2022, amended on June 29, 2022 and July
27, 2022.

The Staff’s comments are repeated below
in bold and are followed by the Company’s responses. Capitalized terms used in this letter but otherwise not defined herein shall
have the meanings ascribed to such terms in the Registration Statement.

Amendment No. 2 to Registration Statement on Form F-3 filed July
27, 2022

Cover page

    1.
    We note your response to comment 1 and reissue it. In this regard, we note that your disclosure on the cover page and page 1 describe current PRC laws and regulations as “prohibit[ing] foreign investment to own more than 50% equity interest of the value- added telecommunication companies ...” Please revise to clearly state that Chinese law prohibits direct foreign investment in your operating companies.

Response: The Company respectfully
advises the Staff that current PRC laws and regulations do not completely prohibit foreign investment in value-added telecommunication
business and they only restrict the foreign invested equity in value-added telecommunication business, which shall not be more than
50%. According to Article 14 of the Special Administrative Measures (Negative List) for Foreign Investment Access (the “2021 version”),
promulgated by PRC Ministry of Commerce (“MOFCOM”) and PRC National Development and Reform Commission (“NDRC”)
in December 2021 and became effective on January 1, 2022, for telecommunication companies: limited to the telecommunication business opened
for foreign investment under the commitment by China when it became a member of WTO, foreign invested equity in valued-added telecommunication
business shall be no more than 50% (except for e-commerce, multi-party domestic communication, storage and transmission, call center),
the basic telecommunication business must be controlled by Chinese parties.

Our operating entity Shanghai Juhao
Information Technology Co., Ltd. (“Shanghai Juhao”) provides online retail for cosmetics, health and nutritional supplements
and household products in China through its retail platforms, www.1juhao.com and mobile app. Shanghai Juhao also offers programs that
enable third-party sellers to distribute their products through our online platforms. According to our PRC counsel Jiangsu Yiyou Tianyuan
Law Firm, the business of Shanghai Juhao falls into the value-added telecom business category in the Negative List.

Therefore, we have to use the VIE
structure for our operating entity in China because foreign ownership of value-added telecom business is subject to restrictions
under current PRC laws and regulations, which prohibit foreign investment to own more than 50% equity interest and will prevent our
Cayman holding company consolidating the financial results of such entity under equity ownership structure.

If you have any further comments or require any
further information or if any questions should arise in connection with this submission, please call Mr. Jeffrey Li at (703) 618-2503
at FisherBroyles, LLP.

    Very truly yours,

    Jowell Global Ltd.

    /s/ Zhiwei Xu

    Zhiwei Xu

    Chief Executive Officer

United States securities and exchange commission logo
August 11, 2022
Zhiwei Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai, China 200082
Re:Jowell Global Ltd.
Amendment No. 2 to Registration Statement on Form F-3
Filed July 27, 2022
File No. 333-264109
Dear Mr. Xu:
            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 July 20, 2022 letter.
Amendment No. 2 to Registration Statement on Form F-3 filed July 27, 2022
Cover page
1.We note your response to comment 1 and reissue it.  In this regard, we note that your
disclosure on the cover page and page 1 describe current PRC laws and regulations as
“prohibit[ing] foreign investment to own more than 50% equity interest of the value-
added telecommunication companies ...” Please revise to clearly state that Chinese law
prohibits direct foreign investment in your operating companies.

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 August 11, 2022 Page 2
 FirstName LastName
Zhiwei Xu
Jowell Global Ltd.
August 11, 2022
Page 2
            Please contact Jennie Beysolow at 202-551-8108 or Lilyanna Peyser at 202-551-3222
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Li, Esq.

CORRESP
1
filename1.htm

jowell global LTD.

July 27, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549-0405

    Attention:
    Jennie Beysolow

    Mara Ransom

    Re:
    Jowell Global Ltd.

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

    Filed June 29, 2022

    File No. 333-264109

Dear Ms. Beysolow and Ms. Ransom:

Jowell Global Ltd. (“JWEL” or the
“Company” and sometimes referred to as “we” or “our”) is submitting this letter and the following
information in response to a letter, dated July 20, 2022, from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-3
(the “Registration Statement”) filed with the Commission on April 4, 2022, amended on June 29, 2022.

Concurrently with the submission of this letter,
the Company is filing Amendment No. 2 to the Registration Statement (the “Amended Registration Statement”) via
EDGAR with the Commission.

The Staff’s comments are repeated below
in bold and are followed by the Company’s responses. In addition to revising the disclosure in response to the Staff’s comments,
the Company has also included other information and data to reflect recent developments.

Amendment No. 1 to Registration Statement on Form
F-3 filed June 29, 2022

Cover page

1. We reissue our comment 1. We note your revised disclosure on the cover page and
page 1 that “[t]he business operations of our VIE include value-added telecommunication services and foreign ownership of value-added
telecommunications services is subject to restrictions under current PRC laws and regulations.” Please revise to clearly state that
Chinese law prohibits direct foreign investment in your operating companies.

Response: We
have revised the disclosure on the cover page and page 1 to clearly state that the business operations of the VIE include
value-added telecommunication services and foreign ownership of value-added telecommunications services is subject to restrictions
under current PRC laws and regulations, which prohibit foreign investment to own more than 50% equity interest of the value-added
telecommunication companies and will prevent the holding company consolidating the financial results of such entities under equity
ownership structure.

2. We note your response to comment 2 and reissue. We note that the company continues
to use terms such as “we” or “our” when describing activities or functions of a VIE. For example, on the cover
page you state: “However, neither any of our subsidiaries or our VIE has made any dividends or other distributions to our
holding company or any U.S. investors as of the date of this prospectus;” and “Investors of our ordinary shares will not own
any equity interests in our VIE and may never hold equity interests in our Chinese operating companies, but instead own shares
of a Cayman Islands holding company.” Please revise throughout your prospectus.

Response: We have changed “our
VIE” to “the VIE” throughout our prospectus.

3. We note your response to comment 3 and reissue in part. Please amend the disclosure
in the summary risk factors to discuss whether any transfers, dividends, or distributions have been made between the holding company,
its subsidiaries, and consolidated VIEs, or to investors, and quantify the amounts where applicable. In this regard, we note that you
provide appropriate disclosure on the cover page and in the prospectus summary and risk factors sections. Provide a cross-reference on
the cover page to the disclosure in the risk factors.

Response:
We have amended the disclosure in the summary risk factors on page 15 to discuss that no dividends or distributions have been made
between the holding company, its subsidiaries, and consolidated VIE, or to investors including U.S. investors. We also provided a cross-reference
on the cover page to the disclosure in the risk factors.

4. We note your response to comment 5 and reissue in part. Please amend the referenced
risk factor section to state that, to the extent cash/assets in the business is in the PRC/Hong Kong or a PRC/Hong Kong entity, the funds/assets
may not be available to fund operations or for other use outside of the PRC/Hong Kong due to interventions in or the imposition of restrictions
and limitations on the ability of you, your subsidiaries, or the consolidated VIEs by the PRC government to transfer cash/assets. Additionally,
please provide a cross reference on the cover page to the discussion of this issue in your summary and summary risk factors section.

Response:
We have revised the referenced risk factor section on page 21 to state that, to the extent cash/assets in the business is in the PRC/Hong
Kong or a PRC/Hong Kong entity, the funds/assets may not be available to fund operations or for other use outside of the PRC/Hong Kong
due to interventions in or the imposition of restrictions and limitations on the ability of us, our subsidiaries, or the consolidated
VIE by the PRC government to transfer cash/assets. We also provide a cross reference on the cover page to the discussion of this issue
in our summary and summary risk factors section.

Prospectus Summary, page 1

5. We note your response to comment 7 and reissue. Please revise to consistently
remove all references to your “control” of the VIE, and revise to clarify that you are the primary beneficiary of the VIE for
accounting purposes, and provide a clear description of the conditions you have satisfied for consolidation of the VIE under U.S. GAAP.

Response:
We have revised our disclosure and removed all references to our “control” of the VIE, and we also revised disclosure to
clarify that we are the primary beneficiary of the VIE for accounting purposes, and have provided a clear description of the conditions
we have satisfied for consolidation of the VIE under U.S. GAAP.

    2

6. We note your response to comment 11, however, the basis for your statement
that “[you], [y]our subsidiaries, or VIE are not 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 our VIE’s business and operations,”
remains unclear. We note that the disclosure goes on to confirm counsel’s opinion as to approvals that may be required by the Cyberspace
Administration of China, however, counsel’s opinion does not appear to extend to the CSRC or any other governmental agency. If you intend
for counsel’s opinion to extend to those agencies, revise to state as much. Alternatively, revise to state the basis that no such permissions
are required.

Response:
We have revised our disclosure on page 2 to include our Chinese counsel’s opinion and statement that we, our subsidiaries, or
VIE are not covered by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China
(CAC) or any other governmental agency that are required to approve the VIE’s business and operations, other than the permits the VIE has already
obtained in the previous sentence.

Our Organizational Structure

Variable Interest Entity Arrangements, page 13

7. We note your response to comment 6 and reissue in part. Please revise to provide additional detail
regarding each contract and arrangement through which you claim to have economic rights and exercise control that results in consolidation
of the VIE’s operations and financial results into your financial statements.

Response: We have revised our disclosure
on page 14 to provide additional detail regarding each contract and arrangement through which we claim to have economic rights and exercise
our contractual rights that results in consolidation of the VIE’s operations and financial results into our financial statements.

If you have any further comments or require any
further information or if any questions should arise in connection with this submission, please call Mr. Jeffrey Li at (703) 618-2503
at FisherBroyles, LLP.

    Very truly yours,

    Jowell Global Ltd.

    /s/ Zhiwei Xu

    Zhiwei Xu

    Chief Executive Officer

3

United States securities and exchange commission logo
July 20, 2022
Zhiwei Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai, China 200082
Re:Jowell Global Ltd.
Amendment No. 1 to Registration Statement on Form F-3
Filed June 29, 2022
File No. 333-264109
Dear Mr. Xu:
            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 May 3, 2022 letter.
Amendment No. 1 to Registration Statement on Form F-3 filed June 29, 2022
Cover page
1.We reissue our comment 1.  We note your revised disclosure on the cover page and page 1
that “[t]he business operations of our VIE include value-added telecommunication
services and foreign ownership of value-added telecommunications services is subject to
restrictions under current PRC laws and regulations.”  Please revise to clearly state that
Chinese law prohibits direct foreign investment in your operating companies.
2.We note your response to comment 2 and reissue.  We note that the company continues
to use terms such as “we” or “our” when describing activities or functions of a VIE.  For
example, on the cover page you state: "However, neither any of our subsidiaries or our
VIE has made any dividends or other distributions to our holding company or any U.S.

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 July 20, 2022 Page 2
 FirstName LastNameZhiwei Xu
Jowell Global Ltd.
July 20, 2022
Page 2
investors as of the date of this prospectus;" and "Investors of our ordinary shares will not
own any equity interests in our VIE and may never hold equity interests in our Chinese
operating companies, but instead own shares of a Cayman Islands holding company."
Please revise throughout your prospectus.
3.We note your response to comment 3 and reissue in part. Please amend the disclosure in
the summary risk factors to discuss whether any transfers, dividends, or distributions have
been made between the holding company, its subsidiaries, and consolidated VIEs, or to
investors, and quantify the amounts where applicable. In this regard, we note that you
provide appropriate disclosure on the cover page and in the prospectus summary and risk
factors sections. Provide a cross-reference on the cover page to the disclosure in the risk
factors.
4.We note your response to comment 5 and reissue in part.  Please amend the
referenced risk factor section to state that, to the extent cash/assets in the business is in the
PRC/Hong Kong or a PRC/Hong Kong entity, the funds/assets may not be available to
fund operations or for other use outside of the PRC/Hong Kong due to interventions in or
the imposition of restrictions and limitations on the ability of you, your subsidiaries, or the
consolidated VIEs by the PRC government to transfer cash/assets.  Additionally, please
provide a cross reference on the cover page to the discussion of this issue in your
summary and summary risk factors section.
Prospectus Summary, page 1
5.We note your response to comment 7 and reissue.  Please revise to consistently remove all
references to your "control" of the VIE, and revise to clarify that you are the primary
beneficiary of the VIE for accounting purposes, and provide a clear description of the
conditions you have satisfied for consolidation of the VIE under U.S. GAAP.
6.We note your response to comment 11, however, the basis for your statement that "[you],
[y]our subsidiaries, or VIE are not 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 our VIE's business and
operations," remains unclear.  We note that the disclosure goes on to confirm counsel's
opinion as to approvals that may be required by the Cyberspace Administration of China,
however, counsel's opinion does not appear to extend to the CSRC or any other
governmental agency.  If you intend for counsel's opinion to extend to those agencies,
revise to state as much.  Alternatively, revise to state the basis that no such permissions
are required.
Our Organizational Structure
Variable Interest Entity Arrangements, page 13
7.We note your response to comment 6 and reissue in part.  Please revise to provide
additional detail regarding each contract and arrangement through which you claim to

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 July 20, 2022 Page 3
 FirstName LastName
Zhiwei Xu
Jowell Global Ltd.
July 20, 2022
Page 3
have economic rights and exercise control that results in consolidation of the VIE’s
operations and financial results into your financial statements.
            Please contact Jennie Beysolow at 202-551-8108 or Mara Ransom at 202-551-3264 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Li, Esq.

CORRESP
1
filename1.htm

jowell
global LTD.

June 29, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549-0405

 Attention: Jennie
Beysolow

Lilyanna Peyser

    Re:
    Jowell Global Ltd.

    Registration Statement on Form F-3

    Filed April 4, 2022

    File No. 333-264109

Dear Ms. Beysolow and Ms. Peyser:

Jowell Global Ltd. (“JWEL” or the
“Company” and sometimes referred to as “we” or “our”) is submitting this letter and the following
information in response to a letter, dated May 3, 2022, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-3 (the “Registration
Statement”) filed with the Commission on April 4, 2022.

Concurrently with the submission of this letter,
the Company is filing Amendment No. 1 to the Registration Statement (the “Amended Registration Statement”) via
EDGAR with the Commission.

The Staff’s comments are repeated below
in bold and are followed by the Company’s responses. In addition to revising the disclosure in response to the Staff’s comments,
the Company has also included other information and data to reflect recent developments.

Registration Statement on Form F-3 filed April 4, 2022

Cover Page

 1. We note your disclosure that the “VIE structure is
used to provide investors with exposure to foreign investment in China-based companies where the business of the operating companies
in China might be prohibited or restricted for foreign investment now or in the future.” Please revise here and elsewhere, as appropriate,
to clarify that Chinese law prohibits direct foreign investment in your operating companies.

Response:
We have revised the disclosure to clarify that the business operations of Shanghai Juhao Information Technology Co., Ltd. include
value-added telecommunication services and foreign ownership of value-added telecommunications services is subject to restrictions under
current PRC laws and regulations on cover page and page 1.

 2. 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. Refrain from using terms such as “we”
or “our” when describing activities or functions of a VIE.

Response:
We have disclosed that we refer to the holding company Jowell Global Ltd. as Jowell Global, the Company, JWEL, the Registrant, the holding
company, we, us, our company, and our on cover page and page ii. We also disclosed clearly that we currently conduct our business through
our VIE Shanghai Juhao Information Technology Co., Ltd. (“Shanghai Juhao”) in China. Shanghai Jowell Information Technology
Co., Ltd. (“Jowell Shanghai”) is a wholly foreign owned enterprise (“WFOE”) and a wholly owned subsidiary of Jowell
Technology Limited (“Jowell HK”), which is a holding company incorporated in Hong Kong and a wholly owned subsidiary of Jowell
Global on cover page and page 1. We will refrain from using terms such as “we” or “our” when describing activities
or functions of a VIE.

 3. You state that no dividends or distributions have been made
between the holding company, its subsidiaries, and consolidated VIEs, or to investors other than U.S. investors. However, we note your
disclosure that “[t]he cash transfer among the holding company, its subsidiaries and VIE is typically transferred through payment
for intercompany services or intercompany borrowing between holding company, subsidiaries and VIE.” We also note your disclosure
on page 9 that “[y]our WFOE receives payments from VIE, pursuant to the VIE Agreements” and that “VIE Shanghai Juhao
made a cash dividend of $1.6 million to its shareholders in July 2019.” Please amend your disclosure here and in the summary risk
factors and risk factors sections to clarify whether any transfers, dividends, or distributions have been made between the holding company,
its subsidiaries, and consolidated VIEs, or to investors, and quantify the amounts where applicable.

Response:
We have revised our disclosure that if our WFOE receives payments from VIE, pursuant to the VIE Agreements, WFOE may make
distribution of such payments to Jowell HK as dividends, however, WFOE currently has not received any payments from the VIE pursuant
to the VIE Agreements on page 10. We have also amended the disclosure on the cover page and in prospectus summary and risk factors
sections to clarify that no dividends or distributions have been made between the holding company, its subsidiaries, and
consolidated VIEs, or to investors, except that our VIE Shanghai Juhao made a cash dividend of $1.6 million to its shareholders in
July 2019 and the cash transfer among the holding company, its subsidiaries and VIE is typically transferred through payment for
investments, intercompany services or intercompany borrowing between holding company, subsidiaries and VIE on page 11.

 4. Where you reference the HFCAA, please also reference the
Accelerating HFCAA; in addition, please provide a cross-reference to the risk factor that describes the HFCAA and Accelerating HFCAA
in more detail. Revise the third paragraph to provide a cross- reference to the risk factors that discuss the risks facing the company
and the offering as a result of your corporate structure. Revise the fourth paragraph to provide a cross- reference to the risk factors
that discuss the risks identified in this paragraph. If the referenced risk factors are contained in a document that is incorporated
by reference, please identify where investors may find them.

Response:
We have revised disclosure to also reference the Accelerating HFCAA where we reference the HFCAA on cover page and page 21. We have also
provided a cross-reference to the risk factor that describes the HFCAA and Accelerating HFCAA in more detail on cover page. We
have revised the third paragraph in the cover page to provide a cross- reference to the risk factors
that discuss the risks facing the company and the offering as a result of our corporate structure and we also have revised the fourth
paragraph in the cover page to provide a cross- reference to the risk factors that discuss the risks identified in that paragraph.

 5. Provide additional detail about the manners in which cash may be transferred throughout your organization,
including the terms under which payments for intercompany services or borrowing may be made and by whom, as well as the terms under which
dividends and other equity distributions may be made and by whom. Discuss whether there are limitations on your ability to transfer cash
between you, your subsidiaries, the consolidated VIEs or investors, and the source of such limitations. Summarize the cash management
policies that dictate how funds are transferred between you, your subsidiaries, the consolidated VIEs or investors and disclose the source
of such policies (e.g., whether they are contractual in nature, pursuant to regulations, etc.). Please amend your disclosure here
and in the summary risk factors and risk factors sections to state that, to the extent cash/assets in the business is in the PRC/Hong
Kong or a PRC/Hong Kong entity, the funds/assets may not be available to fund operations or for other use outside of the PRC/Hong Kong
due to interventions in or the imposition of restrictions and limitations on the ability of you, your subsidiaries, or the consolidated
VIEs by the PRC government to transfer cash/assets. On the cover page, provide cross- references to each of these discussions in the summary
risk factors and risk factors sections. Make conforming changes, as necessary, in the prospectus summary.

Response: We have disclosed on
cover page that no dividends or distributions have been made between the holding company, its subsidiaries, and consolidated VIEs, or
to investors including U.S. investors except that our VIE Shanghai Juhao made a cash dividend of $1.6 million to its shareholders in July
2019 before we became a public company in March 2021. The holding company, its subsidiaries, and VIE do not have any plan to distribute
dividend or settle amounts owed under the VIE Agreements in the foreseeable future. The cash transfer among the holding company, its subsidiaries
and VIE is typically transferred through payment for intercompany investment, services or intercompany borrowing between holding company,
our subsidiaries and VIE. We have provided terms under which payments for intercompany transfers were made and by whom under “Dividend
Distribution and Cash Transfer Between the Holding Company, Subsidiary and VIE.” on page 10 and provided cross-reference on the
cover page.

    2

We have also revised disclosure to discuss
the limitations on our ability to transfer cash between us, our subsidiaries, the consolidated VIE or investors, and the source of such
limitations and provided cross-reference to “Dividend Distribution and Cash Transfer Between the Holding Company, Subsidiary and
VIE.” on page 10. We currently do not have cash management policies and procedures in place that dictate how funds are transferred
through our organization. Rather, the funds can be transferred in accordance with the applicable PRC laws and regulations.

We have also revised
our disclosure on the cover page and in the risk factors section to state that, to the extent cash/assets in the business is in the PRC/Hong
Kong or a PRC/Hong Kong entity, the funds/assets may not be available to fund operations or for other use outside of the PRC/Hong Kong
due to interventions in or the imposition of restrictions and limitations on the ability of us, our subsidiaries, or the consolidated
VIE by the PRC government to transfer cash/assets. We have provided cross- references on the cover page to each of these discussions in
the risk factors in this registration statement or in the risk factors in our 2021 Form 20-F that is incorporated by reference. We also
made conforming changes, as necessary, in the prospectus summary.

 6. Provide additional detail about the manners in which cash
may be transferred throughout your organization, including the terms under which payments for intercompany services or borrowing may
be made and by whom, as well as the terms under which dividends and other equity distributions may be made and by whom.

Response: We have revised disclosure
on the cover page to provide additional details about the manners in which cash may be transferred throughout our organization, including
the terms under which payments for transfers are made and by whom. As of the date of this response, no dividends or distributions have
been made between the holding company, its subsidiaries, and consolidated VIE, or to investors including U.S. investors except that our
VIE Shanghai Juhao made a cash dividend of $1.6 million to its shareholders in July 2019 before we became a public company in March 2021.

Prospectus Summary

Overview, page 1

 7. We note your disclosure that you use a structuring that involves
a VIE based in China and what that entails. We also note your disclosure that you own 100% equity interest in of a WFOE, Jowell Shanghai,
which entered into a series of agreements with the VIE through which you effectively control and derive all of the economic interest
and benefits from the VIE. Please revise the diagram of the company’s corporate structure to identify the groups of persons that
own the equity in Jowell Global Ltd. Provide additional detail regarding each contract and arrangement through which you claim to have
economic rights and exercise control that results in consolidation of the VIE’s operations and financial results into your financial
statements. Describe any other relevant contractual agreements between the entities and how this type of corporate structure may affect
investors and the value of their investment, including how and why the contractual arrangements may be less effective than direct ownership
and that the company may incur substantial costs to enforce the terms of the arrangements.

Response: We have revised the
diagram of the company’s corporate structure to identify the groups of persons that own the equity in Jowell Global Ltd on page
13. We have provided details regarding contracts and arrangements between our WFOE and VIE through which we claim to have economic rights
and exercise control that results in consolidation of the VIE’s operations and financial results into our financial statements on
pages 13 and 14. We have described such contractual agreements between the entities and how this type of corporate structure may affect
investors and the value of their investment, including how and why the contractual arrangements may be less effective than direct ownership
and that the company may incur substantial costs to enforce the terms of the arrangements on page 14.

 8. We note your disclosure in the second paragraph that “[t]he WFOE entered into a series of agreements
with Shanghai Juhao Information Technology Co., Ltd. (“Shanghai Juhao” or “VIE”) and Shanghai Juhao’s shareholders,
through which [you] effectively control and derive all of the economic interest and benefits from Shanghai Juhao.” However, neither
the investors in the holding company nor the holding company itself have an equity ownership in, direct foreign investment in, or control
of, through such ownership or investment, the VIE. Accordingly, please refrain from implying that the contractual agreements are equivalent
to equity ownership in the business of the VIE. Any references to control or benefits that accrue to you because of the VIE should be
limited to a clear description of the conditions you have satisfied for consolidation of the VIE under U.S. GAAP, as disclosed later in
the seventh paragraph of your Summary Overview.

Response:
We have refrained from implying that the contractual agreements are equivalent to equity ownership in the business of the VIE. Any references
to control or benefits that accrue to us because of the VIE are limited to a clear description of the conditions we have satisfied for
consolidation of the VIE under U.S. GAAP.

    3

 9. We note on page 3 that you provide in tabular form condensed consolidating statements that disaggregates
the operations and depicts the financial position, including income and cash flows as of December 31, 2020 and 2019. Please revise to
present major line items for intercompany receivables and amounts associated with intercompany transactions. Any intercompany amounts
should be presented on a gross basis and when necessary, additional disclosure about such amounts should be included in order to make
the information presented not misleading.

Response: We have updated the
tabular form condensed consolidating statements as of December 31, 2021 and 2020 with intercompany amounts presented on a gross basis
and we have also revised to present major line items for intercompany receivables and amounts associated with intercompany transactions
on page 4.

 10. Please provide a summary of risk factors, disclosing the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors. In particular, describe the significant
regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these 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

United States securities and exchange commission logo
May 3, 2022
Zhiwei Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai, China 200082
Re:Jowell Global Ltd.
Registration Statement on Form F-3
Filed April 4, 2022
File No. 333-264109
Dear Mr. Xu:
            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 filed April 4, 2022
Cover Page
1.We note your disclosure that the “VIE structure is used to provide investors with exposure
to foreign investment in China-based companies where the business of the operating
companies in China might be prohibited or restricted for foreign investment now or in the
future.”  Please revise here and elsewhere, as appropriate, to clarify that Chinese law
prohibits direct foreign investment in your operating companies.
2.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.  Refrain from using terms such as “we” or “our” when describing
activities or functions of a VIE.

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 May 3, 2022 Page 2
 FirstName LastNameZhiwei Xu
Jowell Global Ltd.
May 3, 2022
Page 2
3.You state that no dividends or distributions have been made between the holding
company, its subsidiaries, and consolidated VIEs, or to investors other than U.S.
investors.  However, we note your disclosure that “[t]he cash transfer among the holding
company, its subsidiaries and VIE is typically transferred through payment for
intercompany services or intercompany borrowing between holding company, subsidiaries
and VIE.”  We also note your disclosure on page 9 that “[y]our WFOE receives payments
from VIE, pursuant to the VIE Agreements” and that “VIE Shanghai Juhao made a cash
dividend of $1.6 million to its shareholders in July 2019.”  Please amend your disclosure
here and in the summary risk factors and risk factors sections to clarify whether any
transfers, dividends, or distributions have been made between the holding company, its
subsidiaries, and consolidated VIEs, or to investors, and quantify the amounts where
applicable.
4.Where you reference the HFCAA, please also reference the Accelerating HFCAA; in
addition, please provide a cross-reference to the risk factor that describes the HFCAA and
Accelerating HFCAA in more detail.  Revise the third paragraph to provide a cross-
reference to the risk factors that discuss the risks facing the company and the offering as a
result of your corporate structure.  Revise the fourth paragraph to provide a cross-
reference to the risk factors that discuss the risks identified in this paragraph.  If the
referenced risk factors are contained in a document that is incorporated by reference,
please identify where investors may find them.
5.Provide additional detail about the manners in which cash may be transferred throughout
your organization, including the terms under which payments for intercompany services
or borrowing may be made and by whom, as well as the terms under which dividends and
other equity distributions may be made and by whom.  Discuss whether there are
limitations on your ability to transfer cash between you, your subsidiaries, the
consolidated VIEs or investors, and the source of such limitations.  Summarize the cash
management policies that dictate how funds are transferred between you, your
subsidiaries, the consolidated VIEs or investors and disclose the source of such
policies (e.g., whether they are contractual in nature, pursuant to regulations, etc.).  Please
amend your disclosure here and in the summary risk factors and risk factors sections to
state that, to the extent cash/assets in the business is in the PRC/Hong Kong or a
PRC/Hong Kong entity, the funds/assets may not be available to fund operations or for
other use outside of the PRC/Hong Kong due to interventions in or the imposition of
restrictions and limitations on the ability of you, your subsidiaries, or the consolidated
VIEs by the PRC government to transfer cash/assets. On the cover page, provide cross-
references to each of these discussions in the summary risk factors and risk factors
sections.  Make conforming changes, as necessary, in the prospectus summary.
Prospectus Summary
Overview, page 1
6.We note your disclosure that you use a structuring that involves a VIE based in China and

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 May 3, 2022 Page 3
 FirstName LastNameZhiwei Xu
Jowell Global Ltd.
May 3, 2022
Page 3
what that entails.  We also note your disclosure that you own 100% equity interest in of a
WFOE, Jowell Shanghai, which entered into a series of agreements with the VIE through
which you effectively control and derive all of the economic interest and benefits from the
VIE.  Please revise the diagram of the company’s corporate structure to identify the
groups of persons that own the equity in Jowell Global Ltd.  Provide additional detail
regarding each contract and arrangement through which you claim to have economic
rights and exercise control that results in consolidation of the VIE’s operations and
financial results into your financial statements.  Describe any other relevant contractual
agreements between the entities and how this type of corporate structure may affect
investors and the value of their investment, including how and why the contractual
arrangements may be less effective than direct ownership and that the company may incur
substantial costs to enforce the terms of the arrangements.
7.We note your disclosure in the second paragraph that “[t]he WFOE entered into a series of
agreements with Shanghai Juhao Information Technology Co., Ltd. (“Shanghai Juhao” or
“VIE”) and Shanghai Juhao’s shareholders, through which [you] effectively control and
derive all of the economic interest and benefits from Shanghai Juhao.”  However, neither
the investors in the holding company nor the holding company itself have an equity
ownership in, direct foreign investment in, or control of, through such ownership or
investment, the VIE.  Accordingly, please refrain from implying that the contractual
agreements are equivalent to equity ownership in the business of the VIE.  Any references
to control or benefits that accrue to you because of the VIE should be limited to a clear
description of the conditions you have satisfied for consolidation of the VIE under U.S.
GAAP, as disclosed later in the seventh paragraph of your Summary Overview.
8.We note on page 3 that you provide in tabular form condensed consolidating statements
that disaggregates the operations and depicts the financial position, including income and
cash flows as of December 31, 2020 and 2019.  Please revise to present major line items
for intercompany receivables and amounts associated with intercompany transactions.
 Any intercompany amounts should be presented on a gross basis and when necessary,
additional disclosure about such amounts should be included in order to make the
information presented not misleading.
9.Please provide a summary of risk factors, disclosing the risks that your corporate structure
and being based in or having the majority of the company’s operations in China poses to
investors. In particular, describe the significant regulatory, liquidity, and enforcement
risks with cross-references to the more detailed discussion of these 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 the securities you
are registering for sale. Acknowledge any risks that any actions by the Chinese

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 May 3, 2022 Page 4
 FirstName LastNameZhiwei Xu
Jowell Global Ltd.
May 3, 2022
Page 4
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.
10.Please disclose that some of the challenges the company may face in enforcing the VIE
structure and VIE Agreements are due to jurisdictional limits.
11.We note your disclosure that you are not subject to regulations by the entities identified in
the first paragraph on page 2 because the "VIE operates an e-commerce platforms for
online-to-offline sales of cosmetics, health and nutritional supplements and household
products in China and our products and services do not pose national security risks."
Please confirm, if true, that this is the basis for all of counsel's determinations that you are
not subject to such regulations; if that is not the case, please expand your disclosure to
discuss the basis for such conclusions.
12.Please revise the last paragraph on page 2 and the fifth paragraph on page 18 to discuss
the inspection time frames under the HFCAA and Accelerating HFCAA, as well as how
they will affect your company (including in the context of the timing of your last audit
inspection over three years ago).  Further revise these sections to clarify that the United
States Senate has passed the Accelerating Holding Foreign Companies Accountable Act,
which, if enacted, would decrease the number of “non-inspection years” from three years
to two years, and thus, would reduce the time before your securities may be prohibited
from trading or delisted.
Risk Factors
Uncertainties and quick change in the interpretation and enforcement of Chinese laws and
regulations..., page 15
13.We note your disclosure on page 16 of the impact to your operations given the “possibility
that the PRC government will institute a licensing regime or pre-approval requirement
covering [y]our industry at some point in the future.”  Please expand to include the
possibilities that future changes in PRC law also could impact your offering or ability to
conduct offerings.
Enforceability of Civil Liabilities, page 31
14.We note your disclosure that most of your directors and officers are residents of and have
a substantial portion of their assets in jurisdictions other than the United States and that as
a result, it may be difficult for investors to effect service of process within the United
States upon you or your directors and officers, or to enforce against us or them judgments
obtained in United States courts, including judgments predicated upon the civil liability
provisions of the securities laws of the United States or any state in the United States.
Please revise to identify the relevant individuals, and include a risk factor addressing the
challenges of bringing actions and enforcing judgments and liabilities against such

 FirstName LastNameZhiwei Xu
 Comapany NameJowell Global Ltd.
 May 3, 2022 Page 5
 FirstName LastName
Zhiwei Xu
Jowell Global Ltd.
May 3, 2022
Page 5
individuals.
Exhibits
15.Please provide a consent of counsel, Jiangsu Yiyou Tianyuan Law Firm, to be named in
the prospectus.
            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 Jennie Beysolow at 202-551-8108 or Lilyanna Peyser at 202-551-3222
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Li, Esq.

CORRESP
1
filename1.htm

March 11, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Request for Acceleration

    Registration Statement on Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

VIA EDGAR

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, Network 1 Financial
Securities, Inc., as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:00 p.m., Washington D.C. time, on Tuesday, March 16, 2021, or as soon
thereafter as practicable.

Pursuant to Rule 460 under the Act,
we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated February 8, 2021, to selected
dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has
complied and will continue to comply with, and it has been informed or will be informed by participating dealers that they have
complied 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,

Network 1 Financial Securities, Inc.

    By:
    /s/ Adam Pasholk

Name: Adam Pasholk

Title: Managing Director Investment Banking

Network 1 Financial Securities, Inc.

    By:
    /s/ Damon Testaverde

Name: Damon Testaverde

Title: Head of Investment Banking

CORRESP
1
filename1.htm

jowell
global LTD.

VIA EDGAR

March 11, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Request for Acceleration

    Registration Statement Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Jowell Global Ltd (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement
on Form F-1, as amended (the “Form F-1 Registration Statement”) be accelerated to, and that the Form F-1
Registration Statement become effective at, 4:00 p.m., Eastern Time on March 16, 2021, or as soon thereafter as practicable.

The Company also requests that the above-referenced
Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended (the “Exchange Act”),
covering the ordinary shares of the Company, be declared effective concurrently with the Form F-1 Registration Statement (the
“Form 8-A Registration Statement”, together with the Form F-1 Registration Statement, the “Registration
Statements”).

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

The Company understands that the representative
of the underwriters, on behalf of the prospective underwriters of the offering, have joined in this request in a separate letter
filed with the Securities and Exchange Commission (the “Commission”) today.

The Company hereby acknowledges the following:

    ●
    should the Commission or the staff of the Commission (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.

    Very truly yours,

    Jowell Global Ltd.

    By:
    /s/ Zhiwei Xu

    Name:
    Zhiwei Xu

    Title:
    Chief Executive Officer and Chairman of the Board of the Directors

CORRESP
1
filename1.htm

March 9, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Withdrawal of Request for Acceleration

    Registration Statement on Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

VIA EDGAR

Ladies and Gentlemen:

On March 3, 2021, we, as the
representative of the underwriters, filed a letter with the Securities and Exchange Commission via EDGAR requesting, pursuant to
Rule 461 under the Securities Act of 1933, as amended, the acceleration of the effective date of the above-referenced Registration
Statements so that they may be declared effective on March 9, 2021, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.
We are no longer requesting that such Registration Statements be declared effective at this specific date and time and we hereby
formally withdraw such request for acceleration.

Very truly yours,

Network 1 Financial Securities, Inc.

    By:
    /s/ Adam Pasholk

Name: Adam Pasholk

Title: Managing Director Investment Banking

Network 1 Financial Securities, Inc.

    By:
    /s/ Damon Testaverde

Name: Damon Testaverde

Title: Head of Investment Banking

CORRESP
1
filename1.htm

jowell
global LTD.

VIA EDGAR

March 9, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Withdrawal of Request for Acceleration

    Registration Statement Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

Ladies and Gentlemen:

Jowell Global Ltd. (the “Company”) hereby respectfully
requests withdrawal of its acceleration request letter filed as correspondence via EDGAR on March 3, 2021, which requested that
the above-referenced Registration Statements become effective on March 9, 2021 at 4:00 p.m., Eastern Time, or as soon as practicable
thereafter. The Company is no longer requesting that such Registration Statements be declared effective at this specific date and
time and the Company hereby formally withdraws such request for acceleration.

If you have any questions regarding the foregoing, please contact
our counsel at FisherBroyles, LLP, Jeffrey Li at (703) 618-2503.

    Very truly yours,

    Jowell Global Ltd.

    By:
    /s/ Zhiwei Xu

    Name:
    Zhiwei Xu

    Title:
    Chief Executive Officer and Chairman of the Board of the Directors

CORRESP
1
filename1.htm

March 3, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Request for Acceleration

    Registration Statement on Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

VIA EDGAR

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, Network 1 Financial
Securities, Inc., as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:00 p.m., Washington D.C. time, on Tuesday, March 9, 2021, or as soon
thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to advise you that we have distributed as many copies of
the Preliminary Prospectus dated February 8, 2021, to selected dealers, institutions and others as appears to be reasonable to
secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has
complied and will continue to comply with, and it has been informed or will be informed by participating dealers that they have
complied 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,

Network 1 Financial Securities, Inc.

    By:
    /s/ Adam Pasholk

Name: Adam Pasholk

Title: Managing Director Investment Banking

Network 1 Financial Securities, Inc.

    By:
    /s/ Damon Testaverde

Name: Damon Testaverde

Title: Head of Investment Banking

CORRESP
1
filename1.htm

jowell
global LTD.

VIA EDGAR

March 3, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Tatanisha Meadows

        Adam Phippen

        Scott Anderegg

        Lilyanna Peyser

    Re:
    Jowell Global Ltd. (CIK No. 0001805594)

    Request for Acceleration

    Registration Statement Form F-1, as amended (File No. 333-250889)

    Registration Statement on Form 8-A (File No. 001-40145)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Jowell Global Ltd (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement
on Form F-1, as amended (the “Form F-1 Registration Statement”) be accelerated to, and that the Form F-1
Registration Statement become effective at, 4:00 p.m., Eastern Time on March 9, 2021, or as soon thereafter as practicable.

The Company also requests that the above-referenced
Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended (the “Exchange Act”),
covering the ordinary shares of the Company, be declared effective concurrently with the Form F-1 Registration Statement (the
“Form 8-A Registration Statement”, together with the Form F-1 Registration Statement, the “Registration
Statements”).

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

The Company understands that the representative
of the underwriters, on behalf of the prospective underwriters of the offering, have joined in this request in a separate letter
filed with the Securities and Exchange Commission (the “Commission”) today.

The Company hereby acknowledges the following:

    ●
    should the Commission or the staff of the Commission (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.

    Very truly yours,

    Jowell Global Ltd.

    By:
    /s/ Zhiwei Xu

    Name:
    Zhiwei Xu

    Title:
    Chief Executive Officer and Chairman of the Board of the Directors

CORRESP
1
filename1.htm

    Direct
                           Phone: 703.618.2503

        jeffrey.li@fisherBroyles.com

February
8, 2021

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Tatanisha Meadows

    Adam Phippen

    Scott Anderegg

    Lilyanna Peyser

    Re:
    Jowell
        Global Ltd.

        Registration
        Statement on Form F-1/A

        Filed
        December 28, 2020

        File
        No. 333-250889

Ladies
and Gentlemen:

On
behalf of our client, Jowell Global Ltd., a foreign private issuer organized under the laws of Cayman Islands (the “Company”),
we are submitting this letter and the following information in response to a letter, dated January 14, 2021, from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) with
respect to the Company’s Registration Statement on Form F-1/A (the “Registration Statement”) filed
with the Commission on December 28, 2020. Concurrently with the submission of this letter, the Company is filing Amendment No. 2
to the Registration Statement (the “Amended Registration Statement”) via EDGAR with the Commission

To
facilitate your review, we have separately delivered to you a courtesy copy of the Amended Registration Statement, marked to show
changes to the Registration Statement filed with the Commission on December 28, 2020.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used in
this letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information
and data to reflect recent developments.

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

Consolidated
Financial Statements, page F-1

1.
Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or include the representation noted in the
Instruction to Item 8.A.4:2. as an exhibit to your registration statement.

Response:
We have included the Request for Waiver and Representation under Item 8.A.4 of Form 20-F as exhibit 99.2 to the Amended Registration
Statement.

Exhibit
5.1, page II-2

2.
It is inappropriate for counsel to limit its opinion to certain documents; accordingly, please revise the introductory language
to Section 1 to clarify that counsel has examined all documents that it has deemed necessary to render its opinion. In addition,
please delete as inappropriate the assumption in Section 2.3 that “there is nothing contained in the minute book or corporate
records of the Company (which we have not inspected), which would or might affect the opinions set out below.” Further,
please have counsel opine that the warrants are legal, binding obligations of the company. Finally, please revise your exhibit
index to include the Maples & Calder tax opinion as exhibit 8.2 and provide a cross reference to exhibit 5.1.

Response:
Our Cayman counsel has revised its opinion letter and we have filed the revised opinion letter as exhibit 5.1. Our U.S. counsel
has provided its opinion that warrants are legal, binding obligation of the Company which has been filed as exhibit 5. 2. We have
revised our exhibit index to include the Maples & Calder tax opinion as exhibit 8.2 and provided the cross reference to exhibit
5.1.

If
you have any questions or further comments regarding our responses to the Staff’s comments or the Amended Registration Statement,
please contact me by phone at 703-618-2503 or via e-mail at Jeffrey.li@fisherbroyles.com.

    Very truly yours,

    /s/
    Jeffrey Li

    Jeffrey Li

Enclosures

    cc:
    Zhiwei Xu, Chief Executive
    Officer of the Company

    Mei Cai, Chief Financial Officer of the Company

United States securities and exchange commission logo
January 14, 2021
Zhiweu Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai
China 200082
Re:Jowell Global Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed December 28, 2020
File No. 333-250889
Dear Mr. Xu:
            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 7, 2020 letter.
Amendment No. 1 to Registration Statement on Form F-1
Consolidated Financial Statements, page F-1
1.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or
include the representation noted in the Instruction to Item 8.A.4:2. as an exhibit to your
registration statement.

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 January 14, 2021 Page 2
 FirstName LastName
Zhiweu Xu
Jowell Global Ltd.
January 14, 2021
Page 2
Exhibit 5.1, page II-2
2.It is inappropriate for counsel to limit its opinion to certain documents; accordingly,
please revise the introductory language to Section 1 to clarify that counsel has examined
all documents that it has deemed necessary to render its opinion. In addition, please delete
as inappropriate the assumption in Section 2.3 that “there is nothing contained in the
minute book or corporate records of the Company (which we have not inspected), which
would or might affect the opinions set out below.”  Further, please have counsel opine that
the warrants are legal, binding obligations of the company.  Finally, please revise your
exhibit index to include the Maples & Calder tax opinion as exhibit 8.2 and provide a
cross reference to exhibit 5.1.

            You may contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
filename1.htm

Direct
Phone: 703.618.2503

jeffrey.li@fisherBroyles.com

December
28, 2020

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Tatanisha
    Meadows

    Adam
    Phippen

    Scott
    Anderegg

    Lilyanna
    Peyser

    Re:
    Jowell
                                         Global Ltd.

        Registration
        Statement on Form F-1/A

        Filed
        December 28, 2020

        File
        No. 333-250889

Ladies
and Gentlemen:

On
behalf of our client, Jowell Global Ltd, a foreign private issuer organized under the laws of Cayman Islands (the “Company”),
we are submitting this letter and the following information in response to a letter, dated December 7, 2020, from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) with
respect to the Company’s Registration Statement on Form F-1 (the “Registration Statement”) filed
to the Commission on November 23, 2020. Concurrently with the submission of this letter, the Company is filing Amendment No. 1
to the Registration Statement (the “Amended Registration Statement”) via EDGAR with the Commission

To
facilitate your review, we have separately delivered to you a courtesy copy of the Amended Registration Statement, marked to show
changes to the Registration Statement filed with the Commission on November 23, 2020.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used in
this letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information
and data to reflect recent developments.

Form
F-1 filed November 23, 2020

Dilution,
page 48

    1.
    It
    appears you have included intangible assets in the net tangible book value. Please revise or otherwise advise.

Response:
We have revised the net tangible book value on page 50 of the Amended Registration Statement.

    2.
    Please
    revise the narrative preceding the table to highlight the October 21, 2020 sale of shares and its impact on the table. Please
    also show us how you calculated “As adjusted net tangible book value per Ordinary Share attributable to payments by new
    investors” and clarify for us what this line item represents. Consider revising the line item description to clarify.

Response: We have added the narrative in connection
with the October 21, 2020 sale of shares and its impact on the table on pages 50 and 51 of the Amended Registration Statement.
We have also revised our disclosure to provide the clarification regarding the line item and have changed it to “Increase
in net tangible book value per Ordinary Share attributable to payments by new investors” on pages 48 and 49 of the Amended
Registration Statement.

The
Increase in net tangible book value per Ordinary Share attributable to payments by new investors is equal to the pro forma net
tangible book value per Ordinary Share immediately after this offering minus the Net tangible book value per Ordinary Share after
private placement.

If
you have any questions or further comments regarding our responses to the Staff’s comments or the Amended Registration Statement,
please contact me by phone at 703-618-2503 or via e-mail at Jeffrey.li@fisherbroyles.com.

    Very
    truly yours,

    /s/
    Jeffrey Li

    Jeffrey
    Li

Enclosures

    cc:
    Zhiwei
    Xu, Chief Executive Officer of the Company

    Mei
    Cai, Chief Financial Officer of the Company

United States securities and exchange commission logo
December 7, 2020
Zhiweu Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai
China 200082
Re:Jowell Global Ltd.
Registration Statement on Form F-1
Filed November 23, 2020
File No. 333-250889
Dear Mr. Xu:
            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.
Form F-1 filed November 23, 2020
Dilution, page 48
1.It appears you have included intangible assets in the net tangible book value.  Please
revise or otherwise advise.
2.Please revise the narrative preceding the table to highlight the October 21, 2020 sale of
shares and its impact on the table.  Please also show us how you calculated "As adjusted
net tangible book value per Ordinary Share attributable to payments by new investors"
and clarify for us what this line item represents.  Consider revising the line item
description to clarify.
            We remind you that the company and its management are responsible for the accuracy

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 December 7, 2020 Page 2
 FirstName LastName
Zhiweu Xu
Jowell Global Ltd.
December 7, 2020
Page 2
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.
            You may contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
filename1.htm

    Direct
        Phone: 703.618.2503

        jeffrey.li@fisherBroyles.com

November
23, 2020

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Tatanisha
    Meadows

    Adam
    Phippen

    Scott
    Anderegg

    Lilyanna
    Peyser

    Re:
    Jowell
        Global Ltd.

        Registration
        Statement on Form F-1

        Submitted
        November 23, 2020

        CIK
        No. 0001805594

Ladies
and Gentlemen:

On
behalf of our client, Jowell Global Ltd, a foreign private issuer organized under the laws of Cayman Islands (the “Company”),
we are submitting this letter and the following information in response to a letter, dated September 28, 2020, from the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”)
with respect to the Company’s Draft Registration Statement on Form F-1 (the “Draft Registration Statement”)
submitted to the Commission on July 13, 2020, as amended on September 11, 2020. Concurrently with the submission of this letter,
the Company is filing herewith its registration statement on Form F-1 (the “Registration Statement”) and certain
exhibits via EDGAR to the Commission.

To
facilitate your review, we have separately delivered to you a courtesy copy of the Registration Statement, marked to show changes
to the Draft Registration Statement.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used in this letter
but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information
and data to reflect recent developments.

Draft
Registration Statement on Form F-1 Filed September 11, 2020

Management's
Discussion and Analysis of Financial Condition and Results of Operations Results of Operations For the Six Months Ended June 30,
2020 and 2019, page 61

1. We
                                         note your disclosure throughout the filing that the sales of disinfectants and sanitizers
                                         has increased your revenues in the first two quarters of 2020. On page 62, you disclose
                                         that the increase in quantity of health and nutritional supplement products sold was
                                         a main factor to the increase in revenue. On page 63, you disclose that the increase
                                         in quantity of cosmetic disinfectant products and health and nutritional disinfectant
                                         products sold was a main contributor to the increase in cost of sales. However, no quantification
                                         is provided. Please revise to quantify the impact on quantity, revenue and cost of sales
                                         for each product category. Please also disclose how you allocate disinfectant products
                                         to each product category. Finally, consider adding similar quantification in your COVID-19
                                         disclosures elsewhere in the filing or referencing your discussion of results of operations.

Response: Sales of disinfectants and sanitizers mostly
increased in February and March 2020 during the outbreak of COVID-19 in China with an increase of $72,260 or 166% and $31,600 or
38%, comparing to the same periods in 2019, respectively. The COVID-19 outbreak gradually became under control starting in the
2nd quarter of 2020 in China and sales for disinfectants and sanitizers have slowed down accordingly. We have added
such quantification in our COVID-19 disclosures in the Registration Statement.

Our disinfectant and sanitizer products include disinfectant
soap, different types of disinfectant water, hand sanitizers, and other sanitizers (such as bleach and rubbing alcohol). Besides
hand sanitizer, which is categorized as household product, all other disinfectant and sanitizer products are categorized as cosmetic
products.

We sold approximately 33% more disinfectants and
sanitizers products and recognized approximately an additional $149,000 in revenue from such sales in the six months ended June
30, 2020 compared to the six months ended June 30, 2019. The increased revenues from disinfectant and sanitizer products represented
approximately 24% of the total revenue increase in our cosmetic product category in the first six months of 2020. However, the
increase in hand sanitizer products is not the main driver of the increase in revenue and cost of sales of our household products
category and has no impact over our revenue and cost of sales generated from our health and nutritional supplements.

We
have revised our disclosure accordingly on pages 64 and 65 of the Registration Statement.

2. Reference
is made to your discussion of the changes in cost of sales for each product category on page 63. You attribute the difference
to a change in both unit cost and quantity sold. Please revise to quantify the amount of each.

Response: We have revised our disclosure to quantify
the amount of the change in both unit cost and quantity sold on page 65 of the Registration Statement.

3. We
note your response to prior comment 13. On pages 91 and 94, please include the clarifications contained in your response in appropriate
places in your filing. In addition, please consider including GMV for the referenced time periods from sources other than your
mobile platform for purposes of providing investors with clear, complete and comparative disclosure.

Response: We have revised our disclosure to include the clarifications
regarding GMV and percentages from sources other than our mobile platform for the referenced periods on pages 93 and 96 of the
Registration Statement.

If
you have any questions or further comments regarding our responses to the Staff’s comments or the Registration Statement,
please contact me by phone at 703-618-2503 or via e-mail at Jeffrey.li@fisherbroyles.com.

    Very
    truly yours,

    /s/
    Jeffrey Li

    Jeffrey
    Li

Enclosures

    cc:
    Zhiwei
    Xu, Chief Executive Officer of the Company

    Mei
Cai, Chief Financial Officer of the Company

United States securities and exchange commission logo
September 28, 2020
Zhiweu Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai
China 200082
Re:Jowell Global Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted 11, 2020
CIK No. 0001805594
Dear Mr. Xu:
            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 Filed September 11, 2020
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations For the Six Months Ended June 30, 2020 and 2019, page 61
1.We note your disclosure throughout the filing that the sales of disinfectants and sanitizers
has increased your revenues in the first two quarters of 2020.  On page 62, you disclose
that the increase in quantity of health and nutritional supplement products sold was a main
factor to the increase in revenue.  On page 63, you disclose that the increase in quantity of
cosmetic disinfectant products and health and nutritional disinfectant products sold was a
main contributor to the increase in cost of sales.  However, no quantification is provided.
Please revise to quantify the impact on quantity, revenue and cost of sales for each

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 September 28, 2020 Page 2
 FirstName LastName
Zhiweu Xu
Jowell Global Ltd.
September 28, 2020
Page 2
product category.  Please also disclose how you allocate disinfectant products to each
product category.  Finally, consider adding similar quantification in your COVID-19
disclosures elsewhere in the filing or referencing your discussion of results of operations.
2.Reference is made to your discussion of the changes in cost of sales for each product
category on page 63.  You attribute the difference to a change in both unit cost and
quantity sold.  Please revise to quantify the amount of each.
Business, page 86
3.We note your response to prior comment 13.  On pages 91 and 94, please include the
clarifications contained in your response in appropriate places in your filing.  In addtion,
please consider including GMV for the referneced time periods from sources other than
your mobile platform for purposes of providing investors with clear, complete and
comparative disclosure.
            You may contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3336
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
August 6, 2020
Zhiweu Xu
Chief Executive Officer
Jowell Global Ltd.
2nd Floor, No. 285 Jiangpu Road
Yangpu District, Shanghai
China 200082
Re:Jowell Global Ltd.
Draft Registration Statement on Form F-1
Submitted July 13, 2020
CIK No. 0001805594
Dear Mr. Xu:
            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 Submitted July 13, 2020
Prospectus Summary, page 1
1.Please tell us whether you will be deemed a “controlled company” as defined by the
market on which you intend to list your common stock and, if so, whether you intend to
rely on any exemptions as a controlled company. If applicable, please disclose on the
prospectus cover page and in the prospectus summary that you are a controlled company,
and include a risk factor that discusses the effect, risks and uncertainties of being
designated a controlled company.

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 August 6, 2020 Page 2
 FirstName LastName
Zhiweu Xu
Jowell Global Ltd.
August 6, 2020
Page 2
2.In an appropriate place in your summary, please more prominently disclose the
differences in the voting rights of your various classes of stock, and the fact that your
Chairman Mr. Zhiwei Xu, through Jowell Holdings Ltd., beneficially owns all of the
outstanding preferred stock and will therefore control the company after the offering.
3.We note your statement that "[f]or the year ended December 31, 2019, our total revenue
increased by about $37.6 million or 155.4% from about $24.2 million in 2018 to about
$61.8 million in 2019."  In order to provide potential investors with appropriate context,
please also disclose here that net income decreased during this time period, or tell us why
such disclosure is unnecessary.
Corporate History and Structure, page 5
4.We note your corporate diagram on pages 5 and 50.  The chart is difficult to read.  Please
enhance the chart so it is easier to read.
Recent Developments Related to the COVID-19 Outbreak, page 7
5.We note your disclosure on page 8 and elsewhere that "our revenues in the first quarter of
2020 will increase year over year, however, there is no guarantee that our total revenues
will grow or remain at the similar level year over year in the next three quarters of
2020. The situation remains highly uncertain. It is therefore difficult for the Company to
estimate the negative impact on our business or operating results due to COVID-19
pandemic."  Please tell us what consideration you have given to updating the disclosure of
the impact that COVID-19 has had and likely will have on your business now that the
fiscal year is more than half complete.  Please refer to CF Disclosure Guidance: Topic No.
9.
Risk Factors
We historically have received a substantial part of our supplies from our related party suppliers,
..., page 11
6.Please enhance this risk factor to specify the persons and/or names of the
companies that are the related parties that have historically provided your supplies, as well
as the manner in which they are related parties. Please confirm that you will file as
exhibits the agreements you have with your largest and related party suppliers, or tell us
why you do not believe you are required to file such agreements.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
57
7.Please disclose information that allows investors to evaluate the nature of assets held by,
and the operations of, entities apart from the consolidated VIE.  Information should be in
sufficient detail to convey the assets and operations that are not subject to involvement
with the consolidated VIE.  Accompany the disclosure with a discussion of the risks and
uncertainties that may result in deconsolidation of the VIE.

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 August 6, 2020 Page 3
 FirstName LastNameZhiweu Xu
Jowell Global Ltd.
August 6, 2020
Page 3
Liquidity and Capital Resources, page 62
8.Reference is made to the third paragraph on page 63 where you disclose cash and working
capital as of June 30, 2020.  Please tell us whether any debt was issued in the six month
ended June 30, 2020.  If so, please disclose these actions.  Please also disclose the amount
of such cash inside and outside of China.
9.Please revise to describe how cash is transferred through the organization.  Please also
disclose the restricted net assets of consolidated subsidiaries as of December 31, 2019.
Investing Activities, page 64
10.It appears the amount disclosed as cash used in investing activities during 2018 contains a
typographical error.  Please revise so the amount agrees to the amount presented on the
Statement of Cash Flows.
Industry Overview, page 69
11.In the first chart, by footnote or in an explanation to the chart, please explain that "YOY"
means year over year.
Business
Our Sales Channels, page 81
12.Please disclose whether you typically enter into agreements with the authorized retail
stores, suppliers and third-party merchants with whom you do business and, if so, please
describe the typical material terms of those agreements.
Our Internet Platforms , page 84
13.We note your disclosure that approximately 35.84% of your GMV was generated from
your mobile platform in 2018, compared to approximately 41.49% in 2019.  To place this
in context, please provide similar disclosure for your other sales channels, or tell us why
such disclosure is not necessary.
Regulations, page 91
14.Please revise to discuss the effects of the various regulations that you describe here on
your business with a view to understanding how the regulations are applicable to you.
Note 1 - Organization and nature of business, page F-7
15.Please provide disclosure that explains the risks in enforceability of contracts and non-
performance by the VIE.  Please also describe the potential impact of the risks, including
potential for deconsolidation.
16.Please disclose that you attribute all of the VIE's net income or loss to you.  If this is not
the case, please explain.

 FirstName LastNameZhiweu Xu
 Comapany NameJowell Global Ltd.
 August 6, 2020 Page 4
 FirstName LastName
Zhiweu Xu
Jowell Global Ltd.
August 6, 2020
Page 4
Note 3 - Summary of Significant Accounting Policies
Consolidation of Variable Interest Entity, page F-8
17.Please disclose assets of the VIE that can only settle obligations of the VIE and liabilities
for which creditors do not have recourse to the general credit of its primary beneficiary.
Refer to ASC 810-10-50-3.
Revenue Recognition, page F-11
18.Please disclose when control transfers to the customer.  Refer to ASC 606-10-50-12a.
19.Please tell us, and disclose as necessary, the amount of revenue recognized on a net basis
as an agent for each period presented.
Note 15 - Condensed financial information of the parent company, page F-21
20.Please tell us your consideration of disclosing the amount of restricted net assets of
consolidated subsidiaries as of December 31, 2019.
            You may contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services