SecProbe.io

CORRESP
 1
 filename1.htm

 Meihua International Medical Technologies Co.,
Ltd.

 88 Tongda Road, Touqiao Town, Guangling District

 Yangzhou, China, 225000

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Nicholas O'Leary

 February 24, 2026

 Re:
 Meihua International Medical Technologies Co., Ltd.

 Registration Statement on Form F-3 (File No. 333-293682)

 Filed on February 24, 2026

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Meihua International Medical Technologies Co., Ltd. hereby requests acceleration of effectiveness of the above referenced
Registration Statement, so that it will become effective at 5:00 p.m., Eastern Time, on February 25, 2026, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Leyi Lee

 Name:
 Leyi Lee

 Title:
 Chief Executive Officer

 cc:
 Joan Wu, Esq.

 Hunter Taubman Fischer & Li LLC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 18, 2026

Leyi Lee
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People s Republic of China

 Re: Meihua International Medical Technologies Co., Ltd.
 Draft Registration Statement on Form F-3
 Submitted February 13, 2026
 CIK No. 0001835615
Dear Leyi Lee:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
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 Nicholas O'Leary at 202-551-4451 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and Services
cc: Joan Wu, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

MEIHUA
INTERNATIONAL MEDICAL TECHNOLOGIES CO., LTD

88 Tongda Road, Touqiao
Town

Guangling District, Yangzhou, 225000

People’s Republic
of China

February 23, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Juan Grana

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Registration Statement on Form F-1, as amended (Registration No. 333-276882)

    Request for Acceleration of Effectiveness

Acceleration Request

    Requested Date:
    February 27, 2024

    Requested Time:
    11 AM Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 of the
General Rules and Regulations under the Securities Act of 1933, as amended, Meihua International Medical Technologies Co., Ltd. (the
“Registrant”) respectfully requests that the effective date of the Registration Statement on Form F-3 (File No. 333-276882)
(the “Registration Statement”) be accelerated by the Securities and Exchange Commission (the “Commission”) to
11 am Eastern Time on February 27, 2024 or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

(i) should the Commission or the staff, acting
pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action
with respect to the Registration Statement;

(ii) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii) the Registrant may not
assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Megan Penick,
of Dorsey & Whitney LLP, at penick.megan@dorsey.com or by telephone at 201-892-9525, with any questions and please notify us when
this request for acceleration has been granted.

    Sincerely,

    By:
    /s/ Xin Wang

    Name:
    Xin Wang

    Title:
    Chief Financial Officer

    cc:
    Megan J. Penick, Dorsey & Whitney LLP

United States securities and exchange commission logo
February 13, 2024
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Registration Statement on Form F-1
Filed February 6, 2024
File No. 333-276882
Dear Xin Wang:
            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 Juan Grana at 202-551-6034 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

CORRESP
1
filename1.htm

MEIHUA
INTERNATIONAL MEDICAL TECHNOLOGIES CO., LTD

88 Tongda Road, Touqiao
Town

Guangling District, Yangzhou, 225000

People’s Republic
of China

September 28, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and

Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Conlon Danberg and Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Registration Statement on Form F-3, as amended (Registration No. 333-274194)

    Request for Acceleration of Effectiveness

Acceleration Request

    Requested Date:
    September 29, 2023

    Requested Time:
    4:30 PM Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 of the
General Rules and Regulations under the Securities Act of 1933, as amended, Meihua International Medical Technologies Co., Ltd. (the
“Registrant”) respectfully requests that the effective date of the Registration Statement on Form F-3 (File No. 333-274194)
(the “Registration Statement”) be accelerated by the Securities and Exchange Commission (the “Commission”) to
4:30 p.m. Eastern Time on September 29, 2023 or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

(i) should the Commission or the staff, acting
pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action
with respect to the Registration Statement;

(ii) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii) the Registrant may not
assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Megan Penick,
of Michelman & Robinson, LLP, at mpenick@mrllp.com or by telephone at 646-320-4104, with any questions and please notify us when this
request for acceleration has been granted.

    Sincerely,

    By:
    /s/ Xin Wang

    Name:
    Xin Wang

    Title:
    Chief Financial Officer

    cc:
    Megan J. Penick, Michelman & Robinson, LLP

CORRESP
1
filename1.htm

Meihua International Medical Technologies Co.,
Ltd.

88 Tongda Road, Touqiao Town

Guangling District, Yangzhou, 225000

People’s Republic of China

September 25, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Attn:
    Mr. Conlon Danberg

    Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Registration Statement on Form F-3

    Filed August 24, 2023

    File No. 333-274194

Ladies and Gentlemen:

We are hereby transmitting
the response of Meihua International Medical Technologies Co., Ltd., a Cayman company (the “Company,” “we,”
or “our”), to the comment letter we received from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) on September 19, 2023, regarding the Company’s Registration
Statement on Form F-3 filed with the Commission on August 24, 2023. Amendment No. 1 to the Form F-3 (the “Amended No.1 to
Form F-3”) is being submitted to the Commission concurrently with this letter.

For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.

Registration Statement on Form F-3, filed
August 24, 2023

Cover Page

1. We note your statement on the cover page
that “Meihua faces various legal and operational risks and uncertainties as a company with its principal subsidiaries based in and
primarily operating in China.” Please expand on this disclosure to state whether these risks could result in a material change in
your operations and/or the value of your securities or could significantly limit or completely hinder your ability to offer securities
to investors and cause the value of your securities to significantly decline or be worthless. Your disclosure should address how recent
statements and regulatory actions by China’s government, such as those related to the use of variable interest entities and data
security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business, accept foreign investments,
or list on a U.S. or other foreign exchange.

Response: In response to the Staff’s
comment, we updated and expanded upon our disclosure on the cover page to state that risks associated with operating in China could result
in a material change in our operations and/or the value of our securities or could significantly limit or completely hinder our ability
to offer securities to investors and cause the value of our securities to significantly decline or be worthless. In addition, we also
disclosed on the cover page that the impact of the recent statements and regulatory actions by China’s government, such as those
related to the use of data security or anti-monopoly concerns, on us. We respectfully advise the Staff that we do not have variable interest
entity structures.

2. We note your disclosure in the prospectus
summary on page 1 that “[t]he securities offered in this prospectus are the securities of Meihua International, an exempted company
which was incorporated under the laws of the Cayman Islands.” Please include similar disclosure on the cover page of the prospectus.

Response: In response to the Staff’s
comment, we added in the aforementioned disclosure on the cover page.

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

Response: In response to the Staff’s
comment, on the cover page we disclosed that we currently have no intention to issue dividends to our shareholders. In addition, we indicated
that no dividends or other distributions have been made to date from our subsidiaries to our holding company nor have we or any of our
subsidiaries ever paid dividends or made distributions to U.S. investors to date. On the cover page, we also disclosed the transfers made
between the holding company and its subsidiaries to date.

Commonly Used Defined Terms, page iii

4. We note your statement that ““China”
or the “PRC” refers to the People’s Republic of China, including the special administrative regions of Hong Kong and
Macau, and only when this prospectus refers to specific laws and regulations adopted by the PRC and the discretion of China governmental
authorities, reference to “China” or the “PRC” excludes Taiwan and the special administrative regions of Hong
Kong and Macau.” Please clarify that the legal and operational risks associated with operating in China discussed elsewhere

in the prospectus also apply to operations
in Hong Kong and Macau.

Response: In response to the Staff’s
comment, we clarified on page iii under “Commonly Used Defined Terms” that “the legal and operational risks associated
with operating in China discussed elsewhere in this prospectus also apply to any operations we may now or in the future carry out in Hong
Kong or Macau.”

Prospectus Summary, page 1

5. Please revise to quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences or state that no dividends have been made to date.

Response: In response to the Staff’s
comment, we disclosed on page 12 that, as of the date of the prospectus, we have not made any dividends nor distributions to any U.S.
investors.

Key Information Related to Doing Business
in China

Risks and Uncertainties Related to Doing
Business in China

6. We note certain differences between
your disclosure appearing in the “Key Information Related to Doing Business in China” and “Risk Factor” sections
of your prospectus as compared to the disclosure appearing in your Amended Annual Report on Form 20-F filed on August 29, 2023
relating to legal and operational risks associated with operating in China and PRC regulations. As noted in our comment letter to
your Amended Annual Report dated August 25, 2023, it is unclear to us that there were recent changes in the regulatory environment
in the PRC warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to
China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your
operations at any time, or may exert control over operations of your business, which could result in a material change in your
operations and/or the value of the securities you have registered for sale. We remind you that, pursuant to federal securities
rules, the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of the power to
direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by
contract, or otherwise.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the
enforcement of laws and that the rules and regulations in China can change quickly with little advance notice. Because the
disclosure in your prospectus has removed references to PRC laws being inconsistent and unpredictable, the PRC government’s
power to exercise significant oversight and discretion over the conduct of your business, the fact that the regulations to which you
are subject may change rapidly and with little notice, and the level of government involvement in the Chinese economy, we do not
believe that your revised disclosure conveys these risks. We also note your language in your risk factor captioned “We may not
be able to prevent others from the unauthorized use of our intellectual property, which could materially harm our business and
competitive position” noting that you may not be able to effectively protect your intellectual property rights or to enforce
your contractual rights in China “or in other jurisdictions.” However, you disclose that Meihua is not a Chinese
operating company but a Cayman Islands holding company with all operations conducted by its subsidiaries located in mainland China.
Please revise your disclosures in these areas to be consistent with the corresponding disclosures as they exist in your Amended
Annual Report as of August 29, 2023.

Response: In response to the Staff’s
comment, we revised our disclosures on page 3 and page 17 under the “Risk Factor” section to make it consistent with the corresponding
disclosures as they exist in our Annual Report on Form 20-F, as filed with the Commission on August 29, 2023.

    2

Incorporation of Documents by Reference,
page 40

7. Please updated your Incorporation of Documents
by Reference section to refer to your most recent amendment to your Annual Report on Form 20-F which was filed on August 29, 2023.

Response: In response to the Staff’s
comment, we updated our Incorporation of Documents by Reference section on page 40 to refer to Amendment No. 3 to our Annual Report on
Form 20-F, which was filed on August 29, 2023.

Signatures, page II-4

8. We note that the signatures for your three
directors have been provided by your Chief Executive Officer acting as their attorney-in-fact. However, you have not included a signed
power of attorney as an exhibit to the Registration Statement. When you file your next amendment to the Registration Statement, please
include signatures for these directors signed in their own capacity or include signed powers of attorney as exhibits. Please refer to
Item 601(b)(24) of Regulation S-K.

Response: In response to the Staff’s
comment, we updated our signatures so that all directors signed in their own capacity and included a power of attorney for any future
filings.

We thank the Staff in advance
for its review of the foregoing in relation to the Company’s filing of its Amendment No. 1 to Form F-3. Should you have any questions
or concerns, please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104
or mpenick@mrllp.com.

    Sincerely,

    /s/ Xin Wang

    Xin Wang

    Chief Executive Officer

    Meihua International Medical Technologies Co., Ltd.

3

United States securities and exchange commission logo
September 19, 2023
Xin Wang
People’s Republic of China
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Registration Statement on Form F-3
Filed August 24, 2023
File No. 333-274194
Dear Xin Wang:
            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.

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 2
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 2
Registration Statement on Form F-3, filed August 24, 2023
Cover Page
1.We note your statement on the cover page that "Meihua faces various legal and
operational risks and uncertainties as a company with its principal subsidiaries based in
and primarily operating in China." Please expand on this disclosure to state whether these
risks could result in a material change in your operations and/or the value of your
securities or could significantly limit or completely hinder your ability to offer securities
to investors and cause the value of your securities to significantly decline or be worthless.
Your disclosure should address how recent statements and regulatory actions by China’s
government, such as those related to the use of variable interest entities and data security
or anti-monopoly concerns, have or may impact the company’s ability to conduct its
business, accept foreign investments, or list on a U.S. or other foreign exchange.
2.We note your disclosure in the prospectus summary on page 1 that "[t]he securities
offered in this prospectus are the securities of Meihua International, an exempted
company which was incorporated under the laws of the Cayman Islands." Please include
similar disclosure on the cover page of the prospectus.
3.We note your description of how cash is transferred through your organization. Please
revise to disclose your intentions to distribute earnings. State whether any transfers,
dividends, or distributions have been made to date between the holding company, its
subsidiaries, or to investors, and quantify the amounts where applicable. Provide a cross-
reference to the consolidated financial statements.
Commonly Used Defined Terms, page iii
4.We note your statement that "“China” or the “PRC” refers to the People’s Republic of
China, including the special administrative regions of Hong Kong and Macau, and only
when this prospectus refers to specific laws and regulations adopted by the PRC and the
discretion of China governmental authorities, reference to “China” or the “PRC” excludes
Taiwan and the special administrative regions of Hong Kong and Macau." Please clarify
that the legal and operational risks associated with operating in China discussed elsewhere
in the prospectus also apply to operations in Hong Kong and Macau.
Prospectus Summary, page 1
5.Please revise to quantify dividends or distributions made to U.S. investors, the source, and
their tax consequences or state that no dividends have been made to date.
Key Information Related to Doing Business in China
Risks and Uncertainties Related to Doing Business in China, page 2
6.We note certain differences between your disclosure appearing in the "Key Information
Related to Doing Business in China" and "Risk Factor" sections of your prospectus as

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 3
 FirstName LastNameXin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 3
compared to the disclosure appearing in your Amended Annual Report on Form 20-F filed
on August 29, 2023 relating to legal and operational risks associated with operating in
China and PRC regulations. As noted in our comment letter to your Amended Annual
Report dated August 25, 2023, it is unclear to us that there were recent changes in the
regulatory environment in the PRC warranting revised disclosure to mitigate the
challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may
intervene in or influence your operations at any time, or may exert control over operations
of your business, which could result in a material change in your operations and/or the
value of the securities you have registered for sale. We remind you that, pursuant to
federal securities rules, the term “control” (including the terms “controlling,” “controlled
by,” and “under common control with”) as defined in Securities Act Rule 405 means “the
possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and regulations in China
can change quickly with little advance notice. Because the disclosure in your
prospectus has removed references to PRC laws being inconsistent and unpredictable, the
PRC government’s power to exercise significant oversight and discretion over the conduct
of your business, the fact that the regulations to which you are subject may change rapidly
and with little notice, and the level of government involvement in the Chinese
economy, we do not believe that your revised disclosure conveys these risks. We also note
your language in your risk factor captioned "We may not be able to prevent others from
the unauthorized use of our intellectual property, which could materially harm our
business and competitive position" noting that you may not be able to effectively protect
your intellectual property rights or to enforce your contractual rights in China “or in other
jurisdictions.” However, you disclose that Meihua is not a Chinese operating company but
a Cayman Islands holding company with all operations conducted by its subsidiaries
located in mainland China. Please revise your disclosures in these areas to be consistent
with the corresponding disclosures as they exist in your Amended Annual Report as of
August 29, 2023.
Incorporation of Documents by Reference, page 40
7.Please updated your Incorporation of Documents by Reference section to refer to your
most recent amendment to your Annual Report on Form 20-F which was filed on August
29, 2023.
Signatures, page II-4
8.We note that the signatures for your three directors have been provided by your Chief
Executive Officer acting as their attorney-in-fact. However, you have not included a
signed power of attorney as an exhibit to the Registration Statement. When you file your
next amendment to the Registration Statement, please include signatures for these

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 19, 2023 Page 4
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
September 19, 2023
Page 4
directors signed in their own capacity or include signed powers of attorney as
exhibits. Please refer to Item 601(b)(24) of Regulation S-K.
            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 Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-
7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

United States securities and exchange commission logo
September 12, 2023
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 3 to Annual Report on Form 20-F
Filed August 29, 2023
File No. 001-41291
Dear Xin Wang:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

CORRESP
1
filename1.htm

Meihua International Medical Technologies Co.,
Ltd.

88 Tongda Road, Touqiao Town

Guangling District, Yangzhou, 225000

People’s Republic of China

August 29, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Attn:
    Mr. Conlon Danberg

    Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Amendment No. 2 to Annual Report on Form 20-F

    Filed August 21, 2023

    File No. 001-41291

Ladies and Gentlemen:

We are hereby
transmitting the response of Meihua International Medical Technologies Co., Ltd., a Cayman company (the
“Company,” “we,” or “our”), to the comment letter we
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) on August 25, 2023, regarding the Company’s Amendment No. 2 to our Annual Report on
Form 20-F filed with the Commission on August 21, 2023. An Amendment No. 3 to the Form 20-F (the “Amended No.3 to Form
20-F”) is being submitted to the Commission concurrently with this letter.

For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.

Amendment No. 2 to Annual Report on Form
20-F, filed August 21, 2023

Item 3. Key Information, page 1

1. We note the changes you made to your disclosure
appearing in the Risk Factors section of your amended annual report for the fiscal year ended December 31, 2022 relating to legal and
operational risks associated with operating in China and PRC regulations. The annual report discloses information as of your fiscal year
ended December 31, 2022 and it is unclear to us that there were changes in the regulatory environment in the PRC for the period covered
by the report warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any
time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value
of the securities you have registered for sale. We remind you that, pursuant to federal securities rules, the term “control”
(including the terms “controlling,” “controlled by,” and “under common control with”) as defined in
Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management
and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also
sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can
change quickly with little advance notice. Because your revised disclosure has removed references to the PRC government’s power
to exercise significant oversight and discretion over the conduct of your business, the level of government involvement in the Chinese
economy, and the risk factors captioned “PRC’s economic, political and social conditions, as well as changes in any government
policies, laws and regulations, could have a material adverse effect on our business” and “Uncertainties with respect to the
PRC legal system could adversely affect us,” we do not believe that your revised disclosure conveys these risks. We also note that
your disclosure in the “Key Information Related to Doing Business in China” section at the outset of Item 3 continues to reference
the risk factors that were removed in your latest amendment. We further note your revision noting that you may not be able to effectively
protect your intellectual property rights or to enforce your contractual rights in China “or in other jurisdictions.” However,
you disclose that Meihua is not a Chinese operating company but a Cayman Islands holding company with all operations conducted by its
subsidiaries located in mainland China. Please disclose the other jurisdictions where you hold intellectual property. Please restore your
disclosures in these areas to the disclosures as they existed in your annual report as of July 3, 2023.

Response: We respectfully acknowledge
the Staff’s comment and the requirements stated in the Sample Letters to China-Based Companies. In response to the
Staff’s comment, we confirm that the Company is not a Chinese operating company but a Cayman Islands holding company with all
operations conducted by its subsidiaries located in mainland China. Accordingly, we restored our disclosures in our Amendment No. 3
to Form 20-F in the areas the Staff mentioned in their comment letter to the disclosures as they existed in our annual report as
filed with the Commission on July 3, 2023.

We thank the Staff in advance
for its review of the foregoing in relation to the Company’s filing of its Amended No. 3 to Form 20-F. Should you have any questions
or concerns, please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104
or mpenick@mrllp.com.

    Sincerely,

    /s/ Xin Wang

    Xin Wang

    Chief Executive Officer

    Meihua International Medical Technologies Co., Ltd.

United States securities and exchange commission logo
August 25, 2023
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 2 to Annual Report on Form 20-F
Filed August 21, 2023
File No. 001-41291
Dear Xin Wang:
            We have reviewed your August, 21, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 15, 2023 letter.
Amendment No. 2 to Annual Report on Form 20-F, filed August 21, 2023
Item 3. Key Information, page 1
1.We note the changes you made to your disclosure appearing in the Risk Factors section of
your amended annual report for the fiscal year ended December 31, 2022 relating to legal
and operational risks associated with operating in China and PRC regulations. The annual
report discloses information as of your fiscal year ended December 31, 2022 and it is
unclear to us that there were changes in the regulatory environment in the PRC for the
period covered by the report warranting revised disclosure to mitigate the challenges you
face and related disclosures. The Sample Letters to China-Based Companies sought
specific disclosure relating to the risk that the PRC government may intervene in or
influence your operations at any time, or may exert control over operations of your

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 August 25, 2023 Page 2
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
August 25, 2023
Page 2
business, which could result in a material change in your operations and/or the value of
the securities you have registered for sale. We remind you that, pursuant to federal
securities rules, the term “control” (including the terms “controlling,” “controlled by,” and
“under common control with”) as defined in Securities Act Rule 405 means “the
possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and regulations in China
can change quickly with little advance notice. Because your revised disclosure has
removed references to the PRC government’s power to exercise significant oversight and
discretion over the conduct of your business, the level of government involvement in the
Chinese economy, and the risk factors captioned “PRC’s economic, political and social
conditions, as well as changes in any government policies, laws and regulations, could
have a material adverse effect on our business” and “Uncertainties with respect to the
PRC legal system could adversely affect us,” we do not believe that your revised
disclosure conveys these risks. We also note that your disclosure in the “Key Information
Related to Doing Business in China” section at the outset of Item 3 continues to reference
the risk factors that were removed in your latest amendment. We further note your
revision noting that you may not be able to effectively protect your intellectual property
rights or to enforce your contractual rights in China “or in other jurisdictions.” However,
you disclose that Meihua is not a Chinese operating company but a Cayman Islands
holding company with all operations conducted by its subsidiaries located in mainland
China. Please disclose the other jurisdictions where you hold intellectual property. Please
restore your disclosures in these areas to the disclosures as they existed in your annual
report as of July 3, 2023.
            You may contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters. Please
contact Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

CORRESP
1
filename1.htm

Meihua International Medical Technologies Co.,
Ltd.

88 Tongda Road, Touqiao Town

Guangling District, Yangzhou, 225000

People’s Republic of China

August 21, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Attn:
    Mr. Conlon Danberg

    Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Amendment No. 1 to Annual Report on Form 20-F

    Filed July 3, 2023

    File No. 001-41291

Ladies and Gentlemen:

We are hereby
transmitting the response of Meihua International Medical Technologies Co., Ltd. a Cayman company (the
“Company,” “we,” or “our”), to the comment letter we
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) on August 15, 2023, regarding the Company’s Amendment No.1 to our Annual Report on
Form 20-F filed with the Commission on July 3, 2023. An Amendment No. 2 to the Form 20-F (the “Amended No.2 to Form
20-F”) is being submitted to the Commission concurrently with this letter.

For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.

Amendment No. 1 to Annual Report on Form
20-F, filed July 3, 2023

Item 3. Key Information, page 1

1. We note your response to previous comment
1 and re-issue the comment in part. We acknowledge that the Company does not have operations in Macau at this time. However, it is possible
that the Company will commence operations in Macau in the future. Therefore, please expand on your new disclosure at the outset of Item
3. Key Information—D. Risk Factors to state that such legal and operational risks would apply to any operations in Macau. Alternatively,
please remove the carve out for the special administrative region of Macau from the defined term “China” or the “PRC”
in the Use of Certain Defined Terms section.

Response: In response to the
Staff’s comment, we expanded our disclosure at the outset of Item 3. Key Information—D. Risk Factors to state that such
legal and operational risks would apply to any operations in Macau (see page 7 of Amendment No. 2 to Form 20-F). In addition, we
also revised the definition of the term “China” or the “PRC” in the Use of Certain Defined Terms section to
include the special administrative regions of Hong Kong and Macau (see page ii of Amendment No. 2 to Form 20-F).

We thank the Staff in
advance for its review of the foregoing in relation to the Company’s filing of its Amended No. 2 to Form 20-F. Should you have
any questions or concerns, please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone
at (646) 320-4104 or mpenick@mrllp.com.

    Sincerely,

    /s/ Xin Wang

    Xin Wang

    Chief Executive Officer

    Meihua International Medical Technologies Co., Ltd.

United States securities and exchange commission logo
August 15, 2023
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 1 to Annual Report on Form 20-F
Filed July 3, 2023
File No. 001-41291
Dear Xin Wang:
            We have reviewed your July 3, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
June 21, 2023 letter.
Amendment No. 1 to Annual Report on Form 20-F, filed July 3, 2023
Item 3. Key Information, page 1
1.We note your response to previous comment 1 and re-issue the comment in part. We
acknowledge that the Company does not have operations in Macau at this time. However,
it is possible that the Company will commence operations in Macau in the future.
Therefore, please expand on your new disclosure at the outset of Item 3. Key
Information—D. Risk Factors to state that such legal and operational risks would apply to
any operations in Macau. Alternatively, please remove the carve out for the special
administrative region of Macau from the defined term "China" or the "PRC" in the Use of
Certain Defined Terms section.

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 August 15, 2023 Page 2
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
August 15, 2023
Page 2
            You may contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

CORRESP
1
filename1.htm

Meihua International
Medical Technologies Co., Ltd.

88 Tongda Road, Touqiao Town

Guangling District, Yangzhou, 225000

People’s Republic of China

July 3, 2023

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Attn:
    Mr. Conlon Danberg

    Ms. Margaret Schwartz

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Annual Report on Form 20-F

    Filed April 14, 2023

    File No. 001-41291

Ladies and Gentlemen:

We are hereby transmitting
the response of Meihua International Medical Technologies Co., Ltd., a Cayman company (the “Company,” “we,”
or “our”), to the comment letter we received from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) on June 21, 2023 regarding the Company’s Annual
Report on Form 20-F filed with the Commission on April 14, 2023 (the “Form 20-F”). An amendment to the Form
20-F (the “Amended Form 20-F”) addressing the Staff’s comments is being submitted to the Commission concurrently
with this letter.

For your convenience, we have
repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.

Annual Report on Form 20-F, filed April
14, 2023

Introductory Notes

Use of Certain Defined Terms, page ii

1. We note your defined term “China”
excludes “Taiwan and the special administrative regions of Hong Kong and Macau for the purposes of this report only.” Please
clarify that the legal and operational risks associated with operating in China discussed elsewhere in the annual report also apply to
operations in Hong Kong and Macau.

Response: In response to the Staff’s
comment, the Company revised its defined term “China” and deleted the language “excluding Taiwan and the special administrative
regions of Hong Kong and Macau for the purposes of this report only” but added that “and only when this report refers to specific
laws and regulations adopted by the PRC and discretion of China governmental authorities, excludes Taiwan and the special administrative
regions of Hong Kong and Macau” on page ii. The Company also added a disclosure on page 1 stating that “in addition, all the
operational risks associated with being based in and having operations in mainland China as discussed in this “Item 3. Key Information—D.
Risk Factors—Risks Related to Our Business and Industry” also apply to operations in the Hong Kong Special Administrative
Region. With respect to the legal risks associated with being based in and having operations in mainland China as discussed in risk factors
under “Item 3. Key Information—D. Risk Factors—Risks Related to Our Corporate Structure” and “Item 3. Key
Information—D. Risk Factors—Risks Related to Doing Business in China,” the laws, regulations and discretion of mainland
China governmental authorities discussed in this annual report are expected to apply to mainland China entities and businesses only, rather
than entities or businesses in the Hong Kong Special Administrative Region which operates under a different set of laws from mainland
China.”

In addition, the Company respectfully advises
the Staff that the proposed disclosure does not include Macau and Taiwan as the Company does not have operations in Macau or Taiwan.

Item 3. Key Information, page 1

2. At the onset of Item 3, please disclose
prominently that you are not a Chinese operating company but a Cayman Islands holding company with operations conducted by your subsidiaries.
In addition, please provide early in the Key Information section a diagram of the company’s corporate structure.

Response: In response to the Staff’s
comment, the Company added a disclosure that it is not a Chinese operating company but a Cayman Islands holding company with operations
conducted by its subsidiaries located in mainland China. In addition, the Company also provided its corporate structure on page 1 under
“Item 3. Key Information” in the Amended Form 20-F.

3. At the onset of Item 3, please provide prominent
disclosure about the legal and operational risks associated with being based in or having the majority of the company’s operations
in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or the value
of your securities or could significantly limit or completely hinder your ability to offer or continue to offer securities to investors
and cause the value of such securities to significantly decline or be worthless. Your disclosure should address how recent statements
and regulatory actions by China’s government, such as those related to data security or anti-monopoly concerns, have or may impact
the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.

Response: In response to the Staff’s comment, the Company summarized and
consolidated its disclosure of the risks related to its operations in China, including the disclosure noted in the Staff’s comment,
under “Item 3. Key Information” under the heading “Key Information Related to Doing Business in China—Risks and
Uncertainties Related to Doing Business in China” on page 4 of the Amended Form 20-F.

4. At the onset of Item 3, please disclose
the location of your auditor’s headquarters and whether and how the Holding Foreign Companies Accountable Act, as amended by the
Consolidated Appropriations Act, 2023, and related regulations will affect your company.

Response: In response to the Staff’s comment, the Company added disclosure
under Item 3 regarding the location of the Company’s auditor’s headquarters and how the Holding Foreign Companies Accountable
Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations would affect the Company on page 5 of the Amended
Form 20-F.

5. Please clearly disclose how you will refer
to the holding company and subsidiaries when providing the disclosure throughout the document so that it is clear to investors which entity
the disclosure is referencing and which subsidiaries or entities are conducting the business operations. For example, please disclose,
if true, that your subsidiaries conduct operations in China. In this regard, we note your disclosure on page ii that “we,”
“us,” “our company,” “our,” “the Company,” and “Meihua International” may
refer to various entities, including your PRC operating subsidiaries, depending on the context.

Response: In response to the Staff’s
comment, the Company added disclosure under Item 3 to disclose how we will refer to the holding company and subsidiaries when providing
the disclosure throughout the document.

6. At the onset of Item 3, please provide a
clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings. Quantify any
cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and direction of
transfer. Quantify any dividends or distributions that a subsidiary have made to the holding company and which entity made such transfer,
and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign
exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations
on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

Response: In response to the Staff’s
comment, the Company added disclosure under Item 3 under the heading “Cash Flows through Our Company” to describe how cash
is transferred through our organization and our intentions to distribute earnings on page 3 of the Amended Form 20-F. The Company also
quantified cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, as well
as the direction of such transfers, and confirmed that no dividends or distributions have been made to any investors during the reporting
period. In addition, the Company further described any restrictions on foreign exchange and our ability to transfer cash between entities,
across borders, and to U.S. investors.

    2

7. At the onset of Item 3, please disclose
each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer securities to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the China
Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is required to
approve your operations, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions
or approvals have been denied. Please also describe the consequences to you and your investors if you or your subsidiaries: (i) do not
receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or
(iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

Response: In response to the Staff’s
comment, the Company added a disclosure under Item 3 under the headings “Permissions and Approvals Required to be Obtained from
PRC Authorities for our Business Operations” and “Permissions and Approvals Required to be Obtained from PRC Authorities for
our Securities Offerings” on page 5 of the Amended Form 20-F.

8. At the onset of Item 3, please disclose
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. For example, specifically discuss risks
arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations
in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations
at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could
result in a material change in your operations and/or the value of your securities. Acknowledge any risks that any actions by the Chinese
government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers
could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value
of your securities to significantly decline or be worthless.

Response: In response to the Staff’s comment, the Company summarized and
consolidated its disclosure of the risks related to operations in China, including the disclosure noted in the Staff’s comment,
under “Item 3. Key Information” under the heading “Key Information Related to Doing Business in China—Risks and
Uncertainties Related to Doing Business in China” on page 4 of the Amended Form 20-F.

9. Please revise your disclosure to include
in Item 3 a separate “Enforceability of Civil Liability” section regarding the ability to impose liability on officers and directors
located in Hong Kong and China (or elsewhere outside of the U.S., if applicable). This disclosure should be consistent with your risk
factor disclosure under the captions “Certain judgments obtained against us by our shareholders may not be enforceable.” on
page 14 and “You may experience difficulties in effecting service of legal process, enforcing foreign judgments or bringing actions
in the PRC against us or our management named in the report based on foreign laws.” on page 17.

Response: In response to the Staff’s comment, the Company revised and added
a separate section entitled “Enforceability of Civil Liability” under Item 3 on page 6 of the Amended Form 20-F.

    3

Risk Factors

Risks Related to Our Corporate Structure

Certain judgments obtained against us by our shareholders may
not be enforceable, page 14

10. We note your statement that your current
officers “are nationals and residents of countries other than the United States.” Please expand on this risk factor to (i) reference
your current directors in addition to your current officers and (ii) note the specific countries in which they reside. For example, if
true, please state that your directors and officers are located in the PRC and, as such, it will be even more difficult to enforce liabilities
against them or against any directors and officers located outside of the U.S.

Response: In response to the Staff’s
comment, the Company revised the risk factor to state that our directors and officers are located in the PRC and, as such, it will be
difficult to enforce liabilities against them or against any directors and officers located in the PRC on page 20 of the Amended Form
20-F.

We thank the Staff in advance
for its review of the foregoing in relation to the Company’s filing of its Amended Form 20-F. Should you have any questions or concerns,
please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104.

    Sincerely,

    /s/ Xin Wang

    Xin Wang

    Chief Executive Officer

    Meihua International Medical Technologies Co., Ltd.

4

United States securities and exchange commission logo
June 21, 2023
Xin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Annual Report on Form 20-F
Filed April 14, 2023
File No. 001-41291
Dear Xin Wang:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Annual Report on Form 20-F, filed April 14, 2023
Introductory Notes
Use of Certain Defined Terms, page ii
1.We note your defined term "China" excludes "Taiwan and the special administrative
regions of Hong Kong and Macau for the purposes of this report only." Please clarify
that the legal and operational risks associated with operating in China discussed elsewhere
in the annual report also apply to operations in Hong Kong and Macau.
Item 3. Key Information, page 1
2.At the onset of Item 3, please disclose prominently that you are not a Chinese operating
company but a Cayman Islands holding company with operations conducted by your
subsidiaries. In addition, please provide early in the Key Information section a diagram of
the company’s corporate structure.

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 June 21, 2023 Page 2
 FirstName LastNameXin Wang
Meihua International Medical Technologies Co., Ltd.
June 21, 2023
Page 2
3.At the onset of Item 3, please provide prominent disclosure about the legal and operational
risks associated with being based in or having the majority of the company’s operations in
China. Your disclosure should make clear whether these risks could result in a material
change in your operations and/or the value of your securities or could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless. Your disclosure
should address how recent statements and regulatory actions by China’s government, such
as those related to data security or anti-monopoly concerns, have or may impact the
company’s ability to conduct its business, accept foreign investments, or list on a U.S. or
other foreign exchange.
4.At the onset of Item 3, please disclose the location of your auditor’s headquarters and
whether and how the Holding Foreign Companies Accountable Act, as amended by the
Consolidated Appropriations Act, 2023, and related regulations will affect your company.
5.Please clearly disclose how you will refer to the holding company and subsidiaries when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations. For example, please disclose, if true, that your subsidiaries conduct
operations in China. In this regard, we note your disclosure on page ii that “we,” “us,”
“our company,” “our,” “the Company,” and “Meihua International” may refer to various
entities, including your PRC operating subsidiaries, depending on the context.
6.At the onset of Item 3, please provide a clear description of how cash is transferred
through your organization. Disclose your intentions to distribute earnings. Quantify any
cash flows and transfers of other assets by type that have occurred between the holding
company and its subsidiaries, and direction of transfer. Quantify any dividends or
distributions that a subsidiary have made to the holding company and which entity made
such transfer, and their tax consequences. Similarly quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences. Your disclosure should
make clear if no transfers, dividends, or distributions have been made to date. Describe
any restrictions on foreign exchange and your ability to transfer cash between entities,
across borders, and to U.S. investors. Describe any restrictions and limitations on your
ability to distribute earnings from the company, including your subsidiaries, to the parent
company and U.S. investors.
7.At the onset of Item 3, please disclose each permission or approval that you or your
subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer securities to foreign investors. State whether you or your subsidiaries are covered
by permissions requirements from the China Securities Regulatory Commission
(CSRC), Cyberspace Administration of China (CAC) or any other governmental agency
that is required to approve your operations, and state affirmatively whether you have
received all requisite permissions or approvals and whether any permissions or approvals
have been denied. Please also describe the consequences to you and your investors if you
or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 June 21, 2023 Page 3
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
June 21, 2023
Page 3
inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and you are required to obtain such
permissions or approvals in the future.
8.At the onset of Item 3, please disclose 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. For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of
your securities. Acknowledge any risks that any actions by the Chinese government to
exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your
ability to offer or continue to offer securities to investors and cause the value of your
securities to significantly decline or be worthless.
9.Please revise your disclosure to include in Item 3 a separate "Enforceability of Civil
Liability" section regarding the ability to impose liability on officers and directors located
in Hong Kong and China (or elsewhere outside of the U.S., if applicable). This disclosure
should be consistent with your risk factor disclosure under the captions "Certain
judgments obtained against us by our shareholders may not be enforceable." on page 14
and "You may experience difficulties in effecting service of legal process, enforcing
foreign judgments or bringing actions in the PRC against us or our management named in
the report based on foreign laws." on page 17.
Risk Factors
Risks Related to Our Corporate Structure
Certain judgments obtained against us by our shareholders may not be enforceable, page 14
10.We note your statement that your current officers "are nationals and residents of countries
other than the United States." Please expand on this risk factor to (i) reference your
current directors in addition to your current officers and (ii) note the specific countries in
which they reside. For example, if true, please state that your directors and officers are
located in the PRC and, as such, it will be even more difficult to enforce liabilities against
them or against any directors and officers located outside of the U.S.

 FirstName LastNameXin Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 June 21, 2023 Page 4
 FirstName LastName
Xin Wang
Meihua International Medical Technologies Co., Ltd.
June 21, 2023
Page 4
            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.
            You may contact Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Megan J. Penick, Esq.

CORRESP
1
filename1.htm

Prime Number Capital LLC

14 Myrtle Drive

Great Neck, NY 11021

February 14, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Meihua International Medical Technologies Co., Ltd.

    Registration Statement on Form S-1, as amended

    File No. 333-258659

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Prime Number Capital LLC, as the representative of several underwriters of the offering, hereby joins the request of the Company that
the effective date of the above-captioned Registration Statement be accelerated so as to permit it to become effective on February 15,
2022 at 4:00 p.m., Eastern time, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act, we, acting on behalf of the several underwriters, wish
to advise you that, through February 11, 2022, we distributed to each underwriter or dealer, who is reasonably anticipated to be invited
to participate in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus
dated February 8, 2022, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to the Acceleration Request
Letter—Underwriters]

CORRESP
1
filename1.htm

VIA
EDGAR

February
14, 2022

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Division
of Corporation Finance

Washington,
D.C. 20549

    Re:
    Meihua
                                            International Medical Technologies Co., Ltd.

    Amended
    Registration Statement on Form F-1

    File
    No. 333-258659

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Meihua International Medical Technologies Co., Ltd. (the “Company”)
hereby requests acceleration of the effective date of its above-referenced Amended Registration Statement on Form F-1 to 4:00 p.m. Eastern
Standard Time on February 15, 2022, or as soon thereafter as is practicable.

The
Company acknowledges the following:

 ● Should
                                            the U.S. Securities and Exchange Commission (the “Commission”) or the staff,
                                            acting pursuant to delegated authority, declare the filing effective, it does not foreclose
                                            the Commission from taking any action with respect to the filing;

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

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

    Meihua International Medical Technologies Co., Ltd.

    By:
    /s/ Yulin Wang

    Yulin Wang

    Chief Executive Officer

CORRESP
1
filename1.htm

  Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

February 08, 2022

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

    Amendment No. 8 to Registration Statement on
    Form F-1

    Filed February 3, 2022

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated February 7, 2022, commenting on the Company’s Amendment No. 8 to its Registration
Statement on Form F-1 filed February 3, 2022 (the “Registration Statement”).

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

Amendment No. 8 to Form F-1

Capitalization, page 52

1. Please
revise your presentation to include indebtness, such as short-term bank borrowings, as part of your capitalization table.

Response: In response to this comment,
the Company has amended the Registration Statement to include short term bank borrowings in the ‘Capitalization’ table.

2. Please
expand the disclosures for the pro forma column that includes the underwriter’s exercise of the overallotment option in full to disclose
your basis for assuming the underwriters will exercise the option in full. Please also address this comment for your dilution presentation.

Response: In response to this comment
and based upon consultation with Commission staff, the Company has amended the Registration Statement to remove the pro forma
columns that include exercise of the underwriters’ over-allotment option. Information previously reflected in such columns has
been summarized in footnotes to the respective tables.

Dilution, page 54

3. Please
expand the initial sentence to disclose the dollar amount of net tangible book value in addition to the per ordinary share value.

Response: In response to this comment,
the Company has amended the Registration Statement to include the total dollar amount of the Company’s net tangible book value in
the first sentence of the “Dilution’ section.

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

THE CRONE LAW GROUP, P.C.

  By:
  /s/ Joe Laxague

  Joe Laxague, Esq.

United States securities and exchange commission logo
February 7, 2022
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 8 to
Registration Statement on Form F-1
Filed February 3, 2022
File No. 333-258659
Dear Mr. Wang:
            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.
Amendment No. 8 to Form F-1
Capitalization, page 52
1.Please revise your presentation to include indebtness, such as short-term bank
borrowings, as part of your capitalization table.
2.Please expand the disclosures for the pro forma column that includes the underwriter's
exercise of the overallotment option in full to disclose your basis for assuming the
underwriters will exercise the option in full.  Please also address this comment for your
dilution presentation.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 February 7, 2022 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
February 7, 2022
Page 2
Dilution, page 54
3.Please expand the initial sentence to disclose the dollar amount of net tangible book value
in addition to the per ordinary share value.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

  Mark E. Crone

      Managing Partner

mcrone@cronelawgroup.com

                         Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

December 28, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed December 2, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated December 22, 2021, commenting on the Company’s Amendment No. 6 to its Registration
Statement on Form F-1 filed December 2, 2021 (the “Registration Statement”).

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

Amendment No. 6 to Form F-1 filed December 2, 2021

Cover Page

1. Please
disclose on the cover page and in the Summary whether your auditor is subject to the determinations announced by the PCAOB on December
16, 2021.

Response: In response to this comment,
the Company has amended the Registration Statement to include a brief discussion of the PCAOB’s December 16, 2021 report and to
disclose that the Company’s auditor is not subject to the determinations announced in that report.

Summary, page 1

2. We
note your disclosure in the Summary relating to the permissions or approvals that you or your subsidiaries may be required to obtain from
Chinese authorities to operate your business and to offer the securities being registered to foreign investors. Please also describe the
consequences to you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.

    Jane Park

United States Securities and Exchange Commission

December 28, 2021

Page 2 of 2

Response: In response to this comment,
the Company has amended the Registration Statement to include a discussion on these matters in the Summary of Significant Risk Factors
at page 10 and to add that discussion to the relevant Risk Factor at page 33.

Risk Factors, page 21

3. Please
update your disclosure further to reflect that the Commission has adopted rules to implement the HFCAA and that, pursuant to the HFCAA,
the PCAOB has issued its report notifying the Commission of its determination that it is unable to inspect or investigate completely accounting
firms headquartered in mainland China or Hong Kong.

Response: In response to this comment,
the Company has amended the Registration Statement to include this information in the Summary of Significant Risk Factors at page 13 and
to add this information to the relevant Risk Factor at page 37.

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
December 22, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 6 to
Registration Statement on Form F-1
Filed December 2, 2021
File No. 333-258659
Dear Mr. Wang:
            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.
Amendment No. 6 to Form F-1 filed December 2, 2021
Cover Page
1. Please disclose on the cover page and in the Summary whether your auditor is subject to
the determinations announced by the PCAOB on December 16, 2021.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 December 22, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
December 22, 2021
Page 2
Summary, page 1
2.We note your disclosure in the Summary relating to the permissions or approvals that you
or your subsidiaries may be required to obtain from Chinese authorities to operate your
business and to offer the securities being registered to foreign investors.  Please also
describe the consequences to you and your investors if you or your subsidiaries: (i) do not
receive or maintain such permissions or approvals, (ii) inadvertently conclude that such
permissions or approvals are not required, or (iii) applicable laws, regulations, or
interpretations change and you are required to obtain such permissions or approvals in the
future.

Risk Factors, page 21
3.Please update your disclosure further to reflect that the Commission has adopted rules to
implement the HFCAA and that, pursuant to the HFCAA, the PCAOB has issued its
report notifying the Commission of its determination that it is unable to inspect or
investigate completely accounting firms headquartered in mainland China or Hong Kong.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

  Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

December 1, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed November 4, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated November 29, 2021, commenting on the Company’s Amendment No. 5 to its Registration
Statement on Form F-1 filed November 4, 2021 (the “Registration Statement”).

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

Amendment No. 5 to Registration Statement on Form F-1 filed November
4, 2021

Risk Factors, page 21

1.    We
note your correspondence to comments 1 and 2 providing that you do not face any risk of delisting and/or prohibition from trading under
the Holding Foreign Companies Accountable Act as you are currently retaining a U.S. based auditor that is registered with the PCAOB. Please
disclose any material risks to the company and investors if it is later determined that the PCAOB is unable to inspect or investigate
your auditor completely, such as the risk that future audit reports may not be prepared by auditors that are completely inspected by the
PCAOB or the lack of PCAOB inspections of audit work undertaken in China that prevents the PCAOB from regularly evaluating auditors’ audits
and their quality control procedures.

Response: In response to this comment,
the Company has amended the Registration Statement to include an additional risk factor addressing this concern. In addition, a summary
of the new risk factor has been added to the Summary of Significant Risk Factors section.

Jane Park

United States Securities and Exchange Commission

December 1, 2021

Page 2 of 2

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

THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
November 29, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 5 to
Registration Statement on Form F-1
Filed November 4, 2021
File No. 333-258659
Dear Mr. Wang:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our November 18, 2021 letter.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 November 29, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
November 29, 2021
Page 2
Amendment No. 5 to Registration Statement on Form F-1 filed November 4, 2021
Risk Factors, page 21
1.We note your correspondence to comments 1 and 2 providing that you do not face any
risk of delisting and/or prohibition from trading under the Holding Foreign Companies
Accountable Act as you are currently retaining a U.S. based auditor that is registered with
the PCAOB.  Please disclose any material risks to the company and investors if it is later
determined that the PCAOB is unable to inspect or investigate your auditor completely,
such as the risk that future audit reports may not be prepared by auditors that are
completely inspected by the PCAOB or the lack of PCAOB inspections of audit work
undertaken in China that prevents the PCAOB from regularly evaluating auditors' audits
and their quality control procedures.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

  Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

November 22, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

 Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed November 4, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated November 18, 2021, commenting on the Company’s Amendment No. 5 to its Registration
Statement on Form F-1 filed November 4, 2021 (the “Registration Statement”).

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

Amendment No. 5 to Registration Statement on Form F-1 filed November
5, 2021

Risk Factors, page 21

1.
We note from the audit opinion and your disclosure on page 147 that you have a U.S. based auditor that is registered with the PCAOB
and subject to PCAOB inspection. Please disclose any material risks to the company and investors if it is later determined that the PCAOB
is unable to inspect or investigate completely your auditor because of a position taken by an authority in a foreign jurisdiction. For
example, disclose the risk that lack of inspection could cause trading in your securities to be prohibited under the Holding Foreign Companies
Accountable Act and as a result an exchange may determine to delist your securities..

Response: In response to this comment,
the Company respectfully asserts that it faces no risk of delisting and/or prohibition from trading under the provisions of the Holding
Foreign Companies Accountable Act, Act of Dec. 18, 2020, Pub. L. No. 116-222, 134 Stat. 1063 (the “Act”). Section 2(i)(2)(A)
of the Act addresses a covered issuer that: “

. . . retains a registered public accounting
firm that has a branch or office that—

(i) is located in a foreign
jurisdiction; and

(ii) the Board is
unable to inspect or investigate completely because of a position taken by an authority in the foreign jurisdiction described in
clause (i), as determined by the Board

    Jane Park

United States Securities and Exchange Commission

November 22, 2021

Page 2 of 2

The Company’s registered public accounting
firm, Briggs & Veselka Co. (“B&V”), is a U.S. audit firm with offices exclusively in the State of Texas. See, www.bvccpa.com.
As a firm located entirely within the United States, B&V and its offices are subject to the PCAOB inspection requirements. They are
not required to comply with rules by any foreign authority. The Act calls for a penalty of de-listing after three years of non-inspection
of the issuer’s audit firm. Given B&V’s location entirely within the U.S., the Company and B&V face no risk of non-inspection
due to the actions of foreign authorities or for any other reason.

2.
Please expand your risk factor disclosure to discuss that the United States Senate passed the Accelerating Holding Foreign Companies
Accountable Act, which, if enacted, would decrease the number of non-inspection years from three years to two, thus reducing the time
period before your securities may be prohibited from trading or delisted.

Response: In response to this comment,
the Company respectfully references its response to comment no. 1, above. Because the Company and B&V face no risk of a non-inspection
due to the position of any foreign authority, the number of non-inspection years referenced by the Act (either 2 or 3) is not relevant
to the Company.

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
November 18, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 5 to
Registration Statement on Form F-1
Filed November 4, 2021
File No. 333-258659
Dear Mr. Wang:
            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.
Amendment No. 5 to Registration Statement on Form F-1 filed November 5, 2021
Risk Factors, page 21
1.We note from the audit opinion and your disclosure on page 147 that you have a U.S.
based auditor that is registered with the PCAOB and subject to PCAOB inspection.
Please disclose any material risks to the company and investors if it is later determined
that the PCAOB is unable to inspect or investigate completely your auditor because of a
position taken by an authority in a foreign jurisdiction.  For example, disclose the risk that
lack of inspection could cause trading in your securities to be prohibited under the
Holding Foreign Companies Accountable Act and as a result an exchange may determine
to delist your securities.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 November 18, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
November 18, 2021
Page 2
2.Please expand your risk factor disclosure to discuss that the United States Senate passed
the Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the number of non-inspection years from three years to two, thus reducing the
time period before your securities may be prohibited from trading or delisted.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

    Mark E. Crone

    Managing Partner

    mcrone@cronelawgroup.com

    Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

November 4, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

    Attn:
    Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed October 21, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated November 1, 2021, commenting on the Company’s Amendment No. 4 to its Registration
Statement on Form F-1 filed October 21, 2021 (the “Registration Statement”).

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

Amendment No. 4 to Form F-1 filed October 21,
2021

Index to the Consolidated Financial Statements,
page F-1

1.
Please provide interim financial statements for the six-months ended June 30, 2021, along with the corresponding prior year period
in accordance with Item 4.b. of Form F-1 with reference to Item 8.A.5. of Form 20-F.

Response: The Company has amended the Registration
Statement to include its interim financial statements for the six month period ended June 30, 2021 together with the prior year period.
In addition, the various disclosures in the F-1 have been amended to reflect available information for the six months ended June 30, 2021.

Exhibit 23.1, page II-2

2.
Please request a revised consent from Briggs & Veselka Co. that references the correct amendment number. In this regard, the
consent dated October 21, 2021 is included in the fourth amendment to the Form F-1 rather than the third amendment.

Response: The consent from Briggs &
Veselka Co. included with the newly amended Registration Statement references the correct amendment number.

Jane Park

United States Securities and Exchange Commission

November 4, 2021

Page 2 of 2

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
November 1, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 4 to
Registration Statement on Form F-1
Filed October 21, 2021
File No. 333-258659
Dear Mr. Wang:
            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.
Amendment No. 4 to Form F-1 filed October 21, 2021
Index to the Consolidated Financial Statements, page F-1
1.Please provide interim financial statements for the six-months ended June 30, 2021, along
with the corresponding prior year period in accordance with Item 4.b. of Form F-1 with
reference to Item 8.A.5. of Form 20-F.
Exhibit 23.1, page II-2
2.Please request a revised consent from Briggs & Veselka Co. that references the correct
amendment number.  In this regard, the consent dated October 21, 2021 is included in the
fourth amendment to the Form F-1 rather than the third amendment.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 November 1, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
November 1, 2021
Page 2
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

  Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

October 21, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn:	Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed September 24, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated October 18, 2021, commenting on the Company’s Amendment No. 3 to its Registration
Statement on Form F-1 filed September 24, 2021 (the “Registration Statement”).

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

Amendment No. 3 to Registration Statement on
Form F-1 filed September 24, 2021

Cover Page

1. Please
expand your disclosure on the prospectus cover page to provide a description of how cash is transferred through your organization. State
whether any transfers, dividends, or distributions have been made to date.

Response: In response to this comment,
the Company has amended the Registration Statement to display the requested information (which has been included elsewhere in the Registration
Statement) in a prominent position and in bold text on the Prospectus cover page.

Prospectus Summary

Summary of Significant Risk Factors, page 10

2. Please
prominently disclose as significant risk factors the risks related to doing business in China as discussed on page 31.

Response: In response to this comment,
the Company has amended the Registration Statement to include in the ’Summary of Significant Risk Factors’ a summary of substantially
all of the risk factors set forth in the ‘Risks Related to Doing Business in China’ subsection that begins on page 31.

Jane Park

United States Securities and Exchange Commission

October 21, 2021

Page 2 of 2

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
October 18, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 3 to
Registration Statement on Form F-1
Filed September 24, 2021
File No. 333-258659
Dear Mr. Wang:
            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.
Amendment No. 3 to Registration Statement on Form F-1 filed September 24, 2021
Cover Page
1.Please expand your disclosure on the prospectus cover page to provide a description of
how cash is transferred through your organization.  State whether any transfers, dividends,
or distributions have been made to date.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 October 18, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
October 18, 2021
Page 2
Prospectus Summary
Summary of Significant Risk Factors, page 10
2.Please prominently disclose as significant risk factors the risks related to doing business in
China as discussed on page 31.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

 Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Partner

jlaxague@cronelawgroup.com

VIA EDGAR

September 24, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Filed September 13, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated September 21, 2021, commenting on the Company’s Amendment No. 2 to its Registration
Statement on Form F-1 filed September 13, 2021 (the “Registration Statement”).

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

Amendment No. 2 to Form F-1 filed September
13, 2021

Prospectus Summary, page 1

1.
We note that China-based subsidiaries constitute a material part of your consolidated financial statements. Please provide in
tabular form condensed consolidating schedule depicting the financial position, cash flows and results of operations for the parent,
its China-based subsidiaries, and any eliminating adjustments separately - as of the same dates and for the same periods for which
audited consolidated financial statements are required. Highlight the financial statement information related to the China-based
subsidiaries and parent, so an investor may evaluate the nature of assets held by, and the operations of, entities apart from the
China-based subsidiaries, which includes the cash held and transferred among entities.

Response: In response to this
comment, the Company has amended the Registration Statement to add the requested schedules beginning on page 7 of the Registration
Statement. The schedules added beginning on page 7 summarize separately the financial position and cash flows of the parent company
and its China-based subsidiaries, together with eliminating adjustments. As noted below the new tables, the parent company does not
conduct operations separately from its China-based subsidiaries. Accordingly, the results of operations set forth in the audited
consolidated financial statements included in this Prospectus are solely those of the China-based subsidiaries.

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
September 21, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 2 to
Registration Statement on Form F-1
Filed September 13, 2021
File No. 333-258659
Dear Mr. Wang:
            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.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 21, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
September 21, 2021
Page 2
Amendment No. 2 to Form F-1 filed September 13, 2021
Prospectus Summary, page 1
1.We note that China-based subsidiaries constitute a material part of your consolidated
financial statements. Please provide in tabular form condensed consolidating schedule
depicting the financial position, cash flows and results of operations for the parent, its
China-based subsidiaries, and any eliminating adjustments separately - as of the same
dates and for the same periods for which audited consolidated financial statements are
required. Highlight the financial statement information related to the China-based
subsidiaries and parent, so an investor may evaluate the nature of assets held by, and the
operations of, entities apart from the China-based subsidiaries, which includes the cash
held and transferred among entities.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

    Mark E. Crone

    Managing Partner

    mcrone@cronelawgroup.com

    Joe Laxague

    Partner

    jlaxague@cronelawgroup.com

VIA
EDGAR

September
10, 2021

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

Attn: Jane
Park

    Re:
    Meihua
    International Medical Technologies Co., Ltd.

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

    Filed
    August 31, 2021

    File
    No. 333-258659

Dear
Ms. Park:

We
write on behalf of Meihua International Medical Technologies Co., Ltd. (the “Company”) in response to comments by the United
States Securities and Exchange Commission (the “Commission”) in its letter dated September 7, 2021, commenting on the Company’s
Amendment No. 1 to its Registration Statement on Form F-1 filed August 31, 2021 (the “Registration Statement”).

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

Intellectual
Property, page 88

 1. We
note your response to our prior comment 6. Please expand your disclosure of the material terms of the collaboration agreement, where
appropriate, to specify the nature and scope of the patent, the duration of the agreement and royalty term, termination provisions and
the aggregate amounts paid or received to date under the agreement (including any up-front fees), as applicable. Please also specify
the type of patent protection, expected expiration date and applicable jurisdiction of the patent.

Response:
In response to this comment, the Company has amended the Registration Statement to add the additional disclosures requested under the
Patents table on page 89.

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

    THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
September 7, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 1 to
Registration Statement on Form F-1
Filed August 31, 2021
File No. 333-258659
Dear Mr. Wang:
            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 August 24, 2021 letter.
Amendment No. 1 to Form F-1 filed August 31, 2021
Intellectual Property, page 88
1.We note your response to our prior comment 6.  Please expand your disclosure of the
material terms of the collaboration agreement, where appropriate, to specify the nature
and scope of the patent, the duration of the agreement and royalty term, termination
provisions and the aggregate amounts paid or received to date under the agreement
(including any up-front fees), as applicable.  Please also specify the type of patent
protection, expected expiration date and applicable jurisdiction of the patent.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 September 7, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
September 7, 2021
Page 2
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

VIA EDGAR

August 31, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co., Ltd.

    Registration Statement on Form F-1

    Filed August 10, 2021

    File No. 333-258659

Dear Ms. Park:

We write on behalf of Meihua International Medical Technologies
Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the “Commission”)
in its letter dated August 24, 2021, commenting on the Company’s Registration Statement on Form F-1 filed August 10, 2021 (the “Registration
Statement”).

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

Form F-1

Cover Page

1.
Provide prominent disclosure about the legal and operational risks associated
with being based in or having the majority of the company’s operations in China. Your disclosure should make clear whether these
risks could result in a material change in your operations and/or the value of your common stock or could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline
or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s government, such as those
related to the use of variable interest entities and data security or anti-monopoly concerns, has or may impact the company’s ability
to conduct its business, accept foreign investments, or list on an U.S. or other foreign exchange. Your prospectus summary should address,
but not necessarily be limited to, the risks highlighted on the prospectus cover page.

Response: In response to this comment, the Company
has amended the Registration Statement to add bold text disclosures to the Prospectus cover page highlighting the applicable risks noted
in this comment. The risks highlighted in the new Prospectus cover page language are those disclosed more fully in the “Risk Factors”
section, which has been amended to add two additional risk factors as discussed in the response to comments #7 and #8, below. Please be
advised that the Company does not have a variable interest entity structure. In addition, as a medical device manufacturer that does not
collect electronic user data, the Company is not a business of that type that is subject to China’s new cybersecurity policies.
The additional risk factors added in the amended Registration Statement, as well as the bold text disclosures added to the Prospectus
cover page, describe the general risk of potential future regulations being rapidly adopted in the PRC, as well the risk that the PRC
government could, in the future, expand the categories of businesses subject to review prior to undertaking a foreign public offering.

    Jane Park

United States Securities and Exchange Commission

August 31, 2021

Page 2 of 5

Prospectus Summary, page 1

2.
In your summary of risk factors, disclose 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 in the
prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding
the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or
foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of your common
stock. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue
to offer securities to investors and cause the value of such securities to significantly decline or be worthless..

Response: In response to this comment, the Company
has amended the Registration Statement to expand the Summary of Significant Risk Factors. The expanded risk factor summary includes a
summary of the new risk factors added in response to comments #7 and #8, below, as well as other risk factors related to the PRC legal
system and certain limits on the ability of the Company’s PRC subsidiaries to transfer dividends to the Company.

3.
Disclose that trading in your securities may be prohibited under the Holding
Foreign Companies Accountable Act if the PCAOB determines that it cannot inspect or fully investigate your auditor, and that as a result
an exchange may determine to delist your securities. If the PCAOB has been or is currently unable to inspect your auditor, revise your
disclosure to so state.

Response: The Company’s independent auditor,
Briggs & Veselka Co., is a PCAOB registered firm based in Houston, Texas. All audit materials and records relating to the Company
are available for inspection by the PCAOB at Briggs & Veselka Co.’s Houston office, and Briggs & Veselka Co. is regularly
inspected in accordance with PCAOB policies and procedures.  Accordingly, the Company does not believe that the Holding Foreign Companies
Accountable Act will have any material impact on the Company’s listing or otherwise.

    Jane Park

United States Securities and Exchange Commission

August 31, 2021

Page 3 of 5

4.
Disclose each permission that you or your subsidiaries are required to
obtain from Chinese authorities to operate and issue these securities to foreign investors. State whether you or your subsidiaries are
covered by permissions requirements from the CSRC or CAC, and state affirmatively whether you have received all requisite permissions
and whether any permissions have been denied.

Response: Pursuant to the PRC’s Article 6
of the Measures for Cybersecurity Review (Draft for Comments), companies holding data on more than 1 million users must now apply
for cybersecurity approval when seeking listings in other nations due to the risk that such data and personal information could be “affected,
controlled, and maliciously exploited by foreign governments.” The Company’s business belongs to the medical instrument industry
in China, which does not involve the collection of user data, implicate cybersecurity, or involve any other type of restricted industry.
Based on the Company’s understanding of currently applicable PRC laws and regulations, its registered public offering in the U.S.
is not subject to the review or prior approval of the Cyberspace Administration of China (the “CAC”) or the China Securities
Regulatory Commission (the “CRSC”). A new risk factor regarding the potential for a future requirement for the Company to
obtain government approval for foreign offerings has been added under the heading “Risks Related to Doing Business in China”
on page 26. This risk factor has also been added to the summary of significant risk factors.

5.
Provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings. Quantify any cash flows and transfers of other assets by type that have occurred between
the company and its subsidiaries, and direction of transfer. Quantify any dividends or distributions that a subsidiary has made to the
company and which entity made such transfer, and tax consequences. Similarly quantify dividends or distributions made to U.S. investors,
the source, and their tax consequences. Describe any restrictions on foreign exchange and your ability to transfer cash between entities,
across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from your businesses,
including subsidiaries to the parent company and U.S. investors.

Response: In response to this comment, the Company
has amended the Registration Statement on page 8 in the “Corporate History and Structure” section to provide the information
requested by this comment.

Our Competitive Strengths, page 5

6.
We refer to your disclosure in the sixth bullet point relating to the percentage
of profit you receive with respect to certain research products and intellectual property rights once commercialized. Please expand your
disclosure here and under the Intellectual Property section of the Business section on page 85 of such royalty rates and any license or
collaboration agreements you have entered into, including the material terms thereof. Please also file any material collaboration or license
agreement as a exhibit to the registration statement as required by Item 601(b)(10) of Regulation S-K or tell us why it is not material.

Response: In response to this comment, the Company
has added additional disclosure under the bullet point described in the comment, as well as additional disclosures under the heading “Patents”
on page 86. Please also see new Exhibits 10.9.

Risk Factors, page 11

7.
Given the Chinese government’s significant oversight and discretion
over the conduct of your business, please revise to separately highlight the risk that the Chinese government may intervene or influence
your operations at any time, which could result in a material change in your operations and/or the value of your common stock. Also, given
recent statements by the Chinese government indicating an intent to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China based issuers, acknowledge the risk that any such action could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline
or be worthless.

Response: In response to this comment and
comment #8, below, the Company has amended the Registration Statement to add two (2) additional risk factors under the heading “Risks
Related to Doing Business in China” beginning on page 26.

    Jane Park

United States Securities and Exchange Commission

August 31, 2021

Page 4 of 5

8.
In light of recent events indicating greater oversight by the Cyberspace
Administration of China over data security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure
to explain how this oversight impacts your business and your offering and to what extent you believe that you are compliant with the regulations
or policies that have been issued by the CAC to date.

Response: In response to this comment, the Company
has included a discussion of China’s new data security regulations in the second new risk factor added under the heading “Risks
Related to Doing Business in China” on page 26. As discussed in the new risk factor, because the Company’s business belongs
to the medical instrument industry in China, which does not involve the collection of user data, implicate cybersecurity, or involve any
other type of restricted industry, the Company’s registered public offering in the U.S. is not subject to the review or prior approval
of the CAC under China’s new Article 6 of the Measures for Cybersecurity Review (Draft for Comments). In response to comment
#7, however, this new risk factor discloses the risk that the categories of businesses subject to such prior review could be expanded
in the future, thereby limiting or preventing securities offerings by the Company.

1. Organization and Principal Activities

Reorganization and Share Issuance, page F-8

9.
Please expand your disclosures to include the information provided in your
responses to comments 4 and 5 regarding (a) the timing of the payments totaling $1,616,971 for the 1,425,000 ordinary shares along with
the name of the entity that received the $344,739 payment, as Meihua International was not incorporated until November 10, 2020; and (b)
the Acting-in-Concert Agreement that establishes the common control between Meihua International and Kangfu for the periods presented.

Response: In response to this comment, the Company has revised the disclosures
on page F-8 under “Reorganization and Share Issuance.”

2. Summary of Significant Accounting Policies

Segment Reporting, page F-14

10.
As previously requested in comment 7, please provide the enterprise-wide
information required by ASC 280-10-50-38 through 50-41. In this regard, Class I, II, III disposable medical devices is too broad of a
product category and the manufacturing source does not provide product-type information. Further, the geographical information for revenue
disclosure on page F-14 is inconsistent with the disclosures on page 4.

Response: In response to this comment, the
Company has revised the disclosures on page F-14 under “Segment Reporting”. The Company has also revised page 4 disclosure
to solve the inconsistency.

    Jane Park

United States Securities and Exchange Commission

August 31, 2021

Page 5 of 5

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

    THE
    CRONE LAW GROUP, P.C.

    By:
    /s/
    Joe Laxague

    Joe
    Laxague, Esq.

United States securities and exchange commission logo
August 24, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Registration Statement on Form F-1
Filed August 10, 2021
File No. 333-258659
Dear Mr. Wang:
            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.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 August 24, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
August 24, 2021
Page 2
Form F-1
Cover Page
1.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China.  Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of your common stock or could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.  Your disclosure should address how
recent statements and regulatory actions by China’s government, such as those related to
the use of variable interest entities and data security or anti-monopoly concerns, has or
may impact the company’s ability to conduct its business, accept foreign investments, or
list on an U.S. or other foreign exchange. Your prospectus summary should address, but
not necessarily be limited to, the risks highlighted on the prospectus cover page.
Prospectus Summary, page 1
2.In your summary of risk factors, disclose 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 in the prospectus.  For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of
your common stock.  Acknowledge any risks that any actions by the Chinese government
to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.
3.Disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or fully
investigate your auditor, and that as a result an exchange may determine to delist your
securities.  If the PCAOB has been or is currently unable to inspect your auditor, revise
your disclosure to so state.
4.Disclose each permission that you or your subsidiaries are required to obtain from Chinese
authorities to operate and issue these securities to foreign investors.  State whether you or
your subsidiaries are covered by permissions requirements from the CSRC or CAC, and
state affirmatively whether you have received all requisite permissions and whether any
permissions have been denied.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 August 24, 2021 Page 3
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
August 24, 2021
Page 3
5.Provide a clear description of how cash is transferred through your organization.  Disclose
your intentions to distribute earnings.  Quantify any cash flows and transfers of other
assets by type that have occurred between the company and its subsidiaries, and direction
of transfer.  Quantify any dividends or distributions that a subsidiary has made to the
company and which entity made such transfer, and tax consequences.  Similarly quantify
dividends or distributions made to U.S. investors, the source, and their tax consequences.
Describe any restrictions on foreign exchange and your ability to transfer cash between
entities, across borders, and to U.S. investors.  Describe any restrictions and limitations on
your ability to distribute earnings from your businesses, including subsidiaries to the
parent company and U.S. investors.
Our Competitive Strengths, page 5
6.We refer to your disclosure in the sixth bullet point relating to the percentage of profit you
receive with respect to certain research products and intellectual property rights once
commercialized.  Please expand your disclosure here and under the Intellectual Property
section of the Business section on page 85 of such royalty rates and any license or
collaboration agreements you have entered into, including the material terms thereof.
Please also file any material collaboration or license agreement as a exhibit to the
registration statement as required by Item 601(b)(10) of Regulation S-K or tell us why it is
not material.
Risk Factors, page 11
7.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to separately highlight the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of your common stock.  Also, given recent
statements by the Chinese government indicating an intent to exert more oversight and
control over offerings that are conducted overseas and/or foreign investment in China-
based issuers, acknowledge the risk that any such action 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.
8.In light of recent events indicating greater oversight by the Cyberspace Administration of
China over data security, particularly for companies seeking to list on a foreign exchange,
please revise your disclosure to explain how this oversight impacts your business and your
offering and to what extent you believe that you are compliant with the regulations or
policies that have been issued by the CAC to date.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 August 24, 2021 Page 4
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
August 24, 2021
Page 4
1. Organization and Principal Activities
Reorganization and Share Issuance, page F-8
9.Please expand your disclosures to include the information provided in your responses to
comments 4 and 5 regarding (a) the timing of the payments totaling $1,616,971 for
the 1,425,000 ordinary shares along with the name of the entity that received the $344,739
payment, as Meihua International was not incorporated until November 10, 2020; and (b)
the Acting-in-Concert Agreement that establishes the common control between Meihua
International and Kangfu for the periods presented.
2. Summary of Significant Accounting Policies
Segment Reporting, page F-14
10.As previously requested in comment 7, please provide the enterprise-wide information
required by ASC 280-10-50-38 through 50-41.  In this regard, Class I, II, III disposable
medical devices is too broad of a product category and the manufacturing source does not
provide product-type information.  Further, the geographical information for
revenue disclosure on page F-14 is inconsistent with the disclosures on page 4.
            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.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

CORRESP
1
filename1.htm

  Mark E. Crone

Managing Partner

mcrone@cronelawgroup.com

Joe Laxague

Of Counsel

jlaxague@cronelawgroup.com

VIA EDGAR

August 9, 2021

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Washington, D.C. 20549

Attn: Jane Park

    Re:

    Meihua International Medical Technologies Co.,
    Ltd.

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

    Submitted July 16, 2021

    CIK No. 0001835615

Dear Ms. Park:

We write on behalf of Meihua International Medical
Technologies Co., Ltd. (the “Company”) in response to comments by the United States Securities and Exchange Commission (the
“Commission”) in its letter dated July 29, 2021, commenting on the Company’s Amendment No. 2 to Draft Registration Statement
on Form F-1 filed July 16, 2021 (the “Registration Statement”).

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

Prospectus Summary

Implications of Being an Emerging Growth Company,
page 10

1. Please
expand your disclosure to include your conclusion to opt-in to the extended transition period to adopt new or revised accounting standards.
Also provide disclosure that this election may result in your financial statements not be comparable to other entities that adopt new
or revised accounting standards using the public company adoption requirements. Address this comment in your risk factors and in management’s
discussion and analysis sections.

Response: In response to this comment,
the Company has amended the Registration Statement under the “Prospectus Summary” to include a disclosure that, because the
Company has elected to use the extended transition period under the JOBS Act, its financial statements may not be comparable to the financial
statements of public companies that comply with such new or revised accounting standards. Also, additional disclosures regarding this
matter have been added to the risk factor entitled “We are an emerging growth company within the meaning of the Securities Act
and may take advantage of certain reduced reporting requirements.”

Jane Park

United States Securities and Exchange Commission

August 9, 2021

Page 2 of 4

Risks Related to Doing Business in China, page
26

2. Please
include risk factor disclosure, where appropriate, related to the potential impact of the Holding Foreign Companies Accountable Act on
your ability to do business in China.

Response: The Company is not owned or controlled by any governmental entity in
the PRC or elsewhere. The Company’s independent auditor, Briggs & Veselka Co., is a PCAOB registered firm based in Houston,
Texas. All audit materials and records relating to the Company are available for inspection by the PCAOB at Briggs & Veselka Co.’s
Houston office.  Accordingly, the Company does not believe that the Holding Foreign Companies Accountable Act will have any material
impact on its ability to do business.

Our Customers, page 71

3. We
note your response to our prior comment 12. Please clarify whether your direct end user customers and export distributor customers are
based in China. Please also restore your disclosure with respect to your top three customers for the years ended December 31, 2019 and
2020, and also identify which type of customer for each of the three customers.

Response: In response to this comment,
the Registration Statement has been amended at page 71 to clarify that substantially all customers acquiring products directly from the
Company – direct end user customers, domestic distributor customers, and exporting distributor customers – are located in
China.  The disclosure regarding the Company’s top three customers for 2020 and 2019, along with the customer type for each,
has been added to Registration Statement.

Consolidated Statements of Cash Flows, page
F-6

4. Please
tell us why the $344,739 is recognized in equity as a subscription for ordinary shares and included as a financing cash inflow during
fiscal year 2019 and what was provided in exchange. In this regard, we note that when the subscription was released in fiscal year 2020,
no ordinary shares were recognized as outstanding or a corresponding financing cash outflow was recognized during fiscal year 2020.

Response: The Company acknowledges the
Staff’s comment, and respectfully informs the Staff that the Company completed a private offering on December 22, 2020, under which
it issued 1,425,000 ordinary shares to three BVI companies for total consideration of $1,616,971. Of the total consideration, $344,739
was received in December 2019 by one of the Company’s subsidiaries (“Huada”), and $1,272,232 was received in December
2020 by the Company. At the time that the first amount was received, the Company was not yet incorporated, and therefore no actual ordinary
shares were issued. The amount was presented as “ordinary shares subscribed” initially within the Company’s Equity and
then “ordinary shares” and “additional paid-in capital” in 2020, together with the remaining investments received
by the Company.

1. Organization and Principal Activities

Reorganization and Share Issuance, page F-8

5. We
note your responses to comments 17 and 18 along with the expanded disclosure provided to Note 1. Please tell us how you concluded that
the transaction with Yongjun Liu and Yin Liu to acquire 100% ownership of Kangfu represents a corporate reorganization to roll controlled
entities into one legal corporation. In this regard, we note that the three BVI companies, or founders of Meihua, held 2,640,000 ordinary
shares of Meihua, while Yongjun Liu and Yin Liu held 2,000 ordinary shares of Meihua.

Response: The Company acknowledges the
Staff’s comment, and respectfully advises the Staff that Company followed the guidance provided under EITF Issue 02-5 to conclude
the existence of common control.

Jane Park

United States Securities and Exchange Commission

August 9, 2021

Page 3  of 4

On December 18, 2020, Yongjun Liu and Yin Liu and other shareholders
executed an Acting-in-Concert Agreement. The major terms of this agreement are:

 ● The Parties shall inform and discuss with each other and reach a consensus before exercising voting rights in the Company’s
decision making.

 ● If no consensus could be reached by the Parties, the decision made by Yongjun Liu and Yin Liu (who are a couple) prevails.

As a result of the Acting-in-Concert agreement,
Yongjun Liu and Yin Liu has the ultimate control of the Company. The transaction under which Yongjun Liu and Yin Liu to acquired 100%
ownership of Kangfu can be considered as a common control transaction. ASC 805-50-45-5 applies.

Revenue Disaggregation, page F-13

6. We
note your response to comment 21 along with your expanded disclosure. Please tell us your consideration of providing disaggregated revenue
information by domestic versus overseas revenues and also direct sales, domestic distributors, and exporting distributors revenues. In
this regard, we reference your disclosures on page 4 of the Form S-1. Refer to ASC 606-10-55-89 through 55-91 for additional guidance.

Response: The Company acknowledges the
Staff’s comment, and respectfully advises the Staff that the objective of its disaggregated revenue disclosure is to provide the
most useful information to users of its financial statements based on categories that are meaningful to the Company. The assessment requires
judgment, depends on various entity-specific and industry-specific factors and is not subject to a single prescribed factor as the basis
for disaggregation.

In determining the appropriate categories to use
to disaggregate revenue for purposes of its disclosure, the Company has considered the guidance in 606-10-55-89 through 55-91 in its presentation
of the financial statements. The Company determined that the disclosure for major sources of revenues under the following categories as
described in ASC 606 would be most meaningful to the users of the Company’s financial statements:

 ● Type of good (ASC 606-10-55-91(a))

 ● Type of customer (ASC 606-10-55-91(c))

As a result, the Company has revised the disclosure
on Page F-13.

The export sales disclosed in Page 4 is through
exporting distributors which fall into type of customer category. As a result, the Company has revised the disclosure on Page F-13.

Based upon the above considerations, the Company believes it has provided
appropriate disaggregation of revenue.

14. Segment Information, page F-22

7. We
note that you have now concluded that you have 2 reportable segments in accordance with the guidance in ASC 280-10-50. Please provide
the disclosures required by ASC 280-10-50-22 through 50-31. As previously requested, also provide the enterprise-wide information required
by ASC 280-10-50-38 through 50-41. In this regard, we note your disclosures throughout the Form S-1 that you offer three different product
categories, Class I, Class II, and Class II, each representing differing degrees of risk in terms of safety and effectiveness.

Response: The Company acknowledges the Staff’s comment, and respectfully
advises the Staff that our previous response mistakenly interpreted the operating segments. The Company has carefully reassessed the reportable
segments and has concluded it has only one reportable segment. The Company does not have different reporting segments. When making its
determination that its business should be presented as one operating segment, the Company considered the three characteristics of an operating
segment, following the guidance under ASC 280-10-50-1.

Jane Park

United States Securities and Exchange Commission

August 9, 2021

Page  4 of 4

The Company believes that the second and third characteristics of an
operating segment under ASC 289-10-50-1 are not met; therefore, the Company concluded that its operating results should be presented as
one single segment. Specifically, while discrete financial information related to the revenues of self-manufactured products revenue and
resales of sourced disposable medical devices from third party manufacturers is available, discrete financial information related to a
measure of profit or loss for a) self-manufactured products revenue, and b) resales of sourced disposable medical devices from third party
manufacturers are not available. Additionally, while the information regularly reviewed by the Company’s chief operating decision
maker (the “CODM”) includes revenue related to its self-manufactured products revenue and resales of sourced disposable medical
devices from third party manufacturers, it does not include a measure of operating profit or loss for these two revenue streams. In regarding
to Class I, Class II, and Class III products, those are safety measures. Sales of these products were combined within the self-manufactured
products revenue and resales of sourced disposable medical devices from third party manufacturers’ categories. These revenue streams
leverage many common expenses, including but not limited to content development, information technology, marketing, human resources, finance
and legal expenses, and the Company does not separately allocate these common expenses when making decisions about allocating resources
to, or assessing the performance of, its business.

Below are the Company’s responses to the
Staff’s question regarding disclosures made in response to ASC 280-10-50-38 to 42:

 ● Information about Products and Services — As referenced above, the Company has included disclosures
in Note 2 to the financial statements.

 ● Information about Geographic Areas — Our direct export sales accounts for less than 1% of the
total revenue. The disclosure made in Page 3 of this F-1 regarding to export sales were through exporting distributors who are located
in domestic areas.

 ● Information about Major Customers — On page F-10 of the Company’s Form F-1, the Company
has disclosed the revenue concentration.

Corresponding to the response above, the Company
has deleted the Note 14 on Page F-22.

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

THE CRONE LAW GROUP, P.C.

    By:
    /s/ Joe Laxague

    Joe Laxague, Esq.

United States securities and exchange commission logo
July 29, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 2 to
Draft Registration Statement on Form F-1
July 16, 2021
CIK No. 0001835615
Dear Mr. Wang:
            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.
Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary
Implications of Being an Emerging Growth Company, page 10
1.Please expand your disclosure to include your conclusion to opt-in to the extended
transition period to adopt new or revised accounting standards.  Also provide disclosure
that this election may result in your financial statements not be comparable to other
entities that adopt new or revised accounting standards using the public company adoption
requirements.  Address this comment in your risk factors and in management's discussion
and analysis sections.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 29, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 29, 2021
Page 2
Risks Related to Doing Business in China, page 26
2.Please include risk factor disclosure, where appropriate, related to  the potential impact of
the Holding Foreign Companies Accountable Act on your ability to do business in China.
Our Customers, page 71
3.We note your response to our prior comment 12.  Please clarify whether your direct end
user customers and export distributor customers are based in China.  Please also restore
your disclosure with respect to your top three customers for the years ended December 31,
2019 and 2020, and also identify which type of customer for each of the three customers.
Consolidated Statements of Cash Flows, page F-6
4.Please tell us why the $344,739 is recognized in equity as a subscription for ordinary
shares and included as a financing cash inflow during fiscal year 2019 and what was
provided in exchange.  In this regard, we note that when the subscription was released in
fiscal year 2020, no ordinary shares were recognized as outstanding or a corresponding
financing cash outflow was recognized during fiscal year 2020.
1. Organization and Principal Activities
Reorganization and Share Issuance, page F-8
5.We note your responses to comments 17 and 18 along with the expanded disclosure
provided to Note 1.  Please tell us how you concluded that the transaction with Yongjun
Liu and Yin Liu to acquire 100% ownership of Kangfu represents a corporate
reorganization to roll controlled entities into one legal corporation.  In this regard, we note
that the three BVI companies, or founders of Meihua, held 2,640,000 ordinary shares of
Meihua, while Yongjun Liu and Yin Liu held 2,000 ordinary shares of Meihua.
Revenue Disaggregation, page F-13
6.We note your response to comment 21 along with your expanded disclosure.  Please tell
us your consideration of providing disaggregated revenue information by domestic versus
overseas revenues and also direct sales, domestic distributors, and exporting distributors
revenues.  In this regard, we reference your disclosures on page 4 of the Form S-1.  Refer
to ASC 606-10-55-89 through 55-91 for additional guidance.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 29, 2021 Page 3
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 29, 2021
Page 3
14. Segment Information, page F-22
7.We note that you have now concluded that you have 2 reportable segments in accordance
with the guidance in ASC 280-10-50.  Please provide the disclosures required by ASC
280-10-50-22 through 50-31.  As previously requested, also provide the enterprise-wide
information required by ASC 280-10-50-38 through 50-41.  In this regard, we note your
disclosures throughout the Form S-1 that you offer three different product categories,
Class I, Class II, and Class II, each representing differing degrees of risk in terms of safety
and effectiveness.
            You may contact Tracey Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

United States securities and exchange commission logo
July 2, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted June 7, 2021
CIK No. 0001835615
Dear Mr. Wang:
            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.
Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary, page 4
1.We note your disclosure on page 1 and throughout your prospectus that you are a provider
of Class I, II and III disposable medical devices in accordance with China’s National
Medical Device Management regulations.  Please expand your disclosure to discuss
whether the Class I, II and III medical devices that you manufacture and distribute are also
defined as such in accordance with FDA regulations.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 2, 2021 Page 2
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 2, 2021
Page 2
2.We refer to your disclosure on page 1 and elsewhere in your prospectus that you received
FDA registration for over twenty of your products.  Please expand your disclosure of the
FDA registration received, including when and the type of clearance received.
3.We note your disclosure on page 6 that Yangzhou Guanghui Medical Technology Co.,
Ltd., a subsidiary wholly owned by Jiangsu Huadong that was established in December
2020, has no real business.  Please disclose its business purpose.
Prospectus Summary
Our Strategies for Meeting Our Challenges and Further Growth, page 4
4.We note your disclosure that you currently have no agreements or letters of intent for any
acquisitions, partnerships or ventures.  On page 38, you state that you intend to use $10
million of the net proceeds from this offering to acquire a local disposal medical device
manufacturer.  Please revise your disclosures to address this potential inconsistency.
Any failure to maintain effective quality control over our products..., page 12
5.We note your disclosure on pages 13 and 74 relating to the fine of an immaterial amount
for noncompliance of your products with local laws and regulations.  Please expand your
disclosure to specify which products were implicated and the nature of the noncompliance
with regulatory and legal requirements.
We are dependent upon key executives and highly qualified managers..., page 17
6.We refer to your disclosure on page 96 that your employment agreement with Yulin
Wang, the Chief Executive Officer, is for a one year term.  You disclose on page 17 that
the loss of one or more of your key management personnel could have a material adverse
effect on your business.  Please expand your risk factor disclosure to disclose the one year
term of your employment agreement with the Chief Executive Officer and the impact his
departure would have on your business.
We may not be able to prevent others from unauthorized use of our intellectual property..., page
18
7.We note your disclosure on page 80 relating to the patent infringement lawsuit currently
in progress.  Please revise to include risk factor disclosure relating this lawsuit.  Please
also expand your disclosure to address the potentially insufficient availability of
intellectual property rights and protections for companies with material intellectual
property in China.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 2, 2021 Page 3
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 2, 2021
Page 3
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 56
8.Please expand your analysis of accounts receivable to disclose the portion of the total
balance at December 31, 2020 that has subsequently been collected to support your
statement that you do not expect accounts receivable to age over 180 days in the future.
Overview of Chinas Disposable Medical Device Industry, page 58
9.We refer to your disclosure on page 59 of the improvement in China’s global
competitiveness in the low value-added disposable medical device industry in recent
years.  Please also disclose the market size of the countries that compete with China in the
low value-added disposable medical device industry.
Our Products, page 62
10.Please revise the table on pages 63 and 64 to identify the use for each of the top twenty
products disclosed.  Please also disclose whether each of the products listed is your own
brand product or sourced from other manufacturers.
Overview, page 62
11.In an appropriate section of your prospectus, please describe the approval process for
China’s classification of Class I, II and III medical devices and when your top products
received its Class I, II, and III classification and clearance from the Chinese authorities, as
applicable.
Our Customers, page 68
12.We note your disclosure that overseas customers accounted for between 18 and 21% of
your total revenues for the years ended December 31, 2020 and 2019.  Please disclose the
jurisdictions of your top overseas customers.  Please also disclose the breakdown between
domestic and overseas customers of the approximately 6,630 customers you have to date.
Competition, page 71
13.We refer to your disclosure on page 72 relating to your top competitors.  You also disclose
on page 61 that you are a “top player in the region,” which includes the 357 medical
device manufacturers of Class I, II and III medical devices in Touquiao Town.  Please
expand your discussion on the differentiation between you and your competitors,
including the proportion of revenues generated from your top competitors in Touquiao
Town and whether any of your competitors are also focused on providing a one-stop
shopping experience in the disposable medical device industry.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 2, 2021 Page 4
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 2, 2021
Page 4
Patents, page 79
14.We refer to your disclosure on page 79 relating to your fifteen registered patents.  Please
expand your disclosure to include the type of patent protection provided to each patent
listed.  Please also disclose, where appropriate, whether the registered patents relate to any
of the top twenty products referenced on page 63.
Related Party Transactions, page 102
15.Please expand your disclosure of your affiliated entities, Yangzhou Meihua Import and
Export Co., Ltd., Yangzhou Yada Powder Metallurgy Co., Ltd., Shanghai Xinya
Pharmaceutical Hanjian Co., Ltd. and Jiangsu Qinqin Group Yangzhou Hujun Food Co.,
Ltd., controlled by the son of your Chairman and shareholder, Yongjun Liu, and the
business purpose and operations of each affiliate.  Please also include the type of products
you provided to the specified affiliated entities.
Financial Statements
1. Organization and Principal Activities
Principal Activities , page F-7
16.Please expand your disclosures to clarify that all operating entities have been directly or
indirectly 100% owned by Kangfu for all periods presented.
Restructuring and Share Issuance, page F-8
17.We note your disclosures that Yongjun Lui and Yin Lui exchanged their 100% ownership
of Kangfu for 15,933,000 ordinary shares in Meihua.  As such, please tell us why you
have retroactively reflected 20,000,000 ordinary shares to January 1, 2019, including the
authoritative literature that supports your accounting.
18.Please disclose the consideration received in exchange for the 2,640,000 ordinary shares
to the three BVI companies.
2. Summary of Significant Accounting Policies
Certain Risks and Concentration, page F-10
19.Please revise your presentation of customer concentrations for total sales and accounts
receivable to comply with the requirements in ASC 280-10-50-42, which notes that the
customer name does not need to be disclosed but rather may be identified and
distinguished from other major customers by reference as customer A, customer B,
customer C.  This will allow an investor to understand if there are any changes with the
major customers between the periods presented.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 2, 2021 Page 5
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 2, 2021
Page 5
Intangible Assets, page F-12
20.Please expand your disclosure of the estimated useful life to provide the disclosure for
each type of intangible asset, as the range provided of 5-50 years is very broad.
Revenue Recognition, page F-13
21.We note the information regarding revenues provided on page 2 of your Form F-1.  Please
tell us your consideration of the guidance in ASC 606-10-50-5 and 606-10-55-89 through
55-91 for providing disaggregated revenue in your footnotes. In addition, explain how you
considered the guidance in ASC 606-10-55-35 to 39 with regard to principal versus agent
for resales of products from other manufacturers.
Segment Reporting, page F-14
22.Please provide the disclosures required by ASC 280-10-50-38 through 50-41.  For the
information about products and services portion of the disclosures, we note your
disclosures on page 48 listing out your main product lines.
Recently Issued Accounting Standards, page F-15
23.We note that you have not adopted ASU No. 2016-02, Leases (Topic 842), even though
public entities would have adopted on January 1, 2020 for a December 31 fiscal year end.
We further note your statement on page 8 that you have elected to “opt out” of the new or
revised financial accounting standards and will comply as required for public companies,
which is an irrevocable decision.  Please advise.
13. Statutory Surplus Reserves, page F-20
24.Please expand your disclosures to include the information required by Article 4-08(e) of
Regulation S-X.  To the extent applicable, also include the Schedule I information
required by Article 5-04 of Regulation S-X.  Finally, expand your disclosures to include
the amount of reserves remaining to be provided pursuant to PRC statutory laws.
15. Subsequent Events, page F-22
25.Please disclose the specific date through which subsequent events were evaluated in
accordance with ASC 855-10-50-1.
General
26.Please expand your disclosure of the corporate governance differences in accordance with
Item 16G of Form 20-F.  For example, consider including a table comparing differences in
corporate governance practices between domestic issues and foreign private issuers and
how such differences may impact investors.

 FirstName LastNameYulin  Wang
 Comapany NameMeihua International Medical Technologies Co., Ltd.
 July 2, 2021 Page 6
 FirstName LastName
Yulin  Wang
Meihua International Medical Technologies Co., Ltd.
July 2, 2021
Page 6
27.We note that you have checked the Rule 415 box on your outside cover page, yet
disclosures elsewhere indicate that this is a firm commitment, underwritten offering.
Please advise or revise accordingly.
28.We note that the company websites listed on page ii of the prospectus do not appear to
work.  Please revise accordingly.
29.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.
            You may contact Tracy Houser at 202-551-3736 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague, Esq.

United States securities and exchange commission logo
January 6, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
Re:Meihua International Medical Technologies Co., Ltd.
Draft Registration Statement on Form F-1
Submitted December 31, 2020
CIK No. 0001835615
Dear Mr. Wang:
            Our initial review of your draft registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act of 1933, the rules and
regulations thereunder and the requirements of the form.  More specifically, your draft
registration statement does not include an audit report and does not identify your independent
registered public accounting firm.  Please ensure that the financial statements are audited in
accordance with the standards of the PCAOB and that your auditor complies with the
Commission’s standards for auditor independence.  Refer to Item 4.a of Form F-1, Instruction 2
to Item 8.A.2 of Form 20-F, and Article 2 of Regulation S-X.
            We will provide more detailed comments relating to your draft registration statement
following our review of a substantive amendment that addresses these deficiencies.
            Please contact Kasey Robinson at 202-551-5880 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joe Laxague