SecProbe.io

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ZJK Industrial Co., Ltd.

March 25, 2026

Via EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Ms.
    Erin Donahue

    Re:
    ZJK Industrial
    Co., Ltd.

    Registration Statement
    on Form F-3, as amended

    Initially Filed on February
    17, 2026

    File No. 333-293519

Dear Ms. Erin Donahue:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, ZJK Industrial Co., Ltd. hereby requests that
the effectiveness of the above-referenced Registration Statement on Form F-3, as amended, be accelerated to and that the Registration
Statement become effective at 4:30 p.m., Eastern Time, on March 27, 2026, or as soon thereafter as practicable.

    Very truly yours,

    ZJK Industrial Co., Ltd.

    By:
    /s/ Ning Ding

    Name:
    Ning Ding

    Title:
    Chief Executive Officer

February 25, 2026
Ning Ding
Chief Executive Officer
ZJK Industrial Co., Ltd.
No.8, Jingqiang Road, 138 Industrial Zone,
Xiuxin Community, Kengzi Town,
Pingshan New Area, Shenzhen
People’s Republic of China, 518122
Re:ZJK Industrial Co., Ltd.
Registration Statement on Form F-3
Filed February 17, 2026
File No. 333-293519
Dear Ning Ding:
            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 Erin Donahue at 202-551-6063 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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ZJK INDUSTRIAL CO., LTD.

September 25, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    ZJK Industrial Co., Ltd.

    Registration Statement on Form F-1, as amended (File No. 333- 280371)

    Request For Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended, ZJK Industrial Co., Ltd. (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1/A (the “F-1 Registration
Statement”) be accelerated to and that the F-1 Registration Statement become effective at 4:00 p.m., Eastern Time, on September
27, 2024, or as soon thereafter as practicable.

If you have any further questions,
please contact the Company’s U.S. securities counsel, Anna J. Wang, Esq., of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

ZJK Industrial Co., Ltd.

By:
/s/ Ning Ding

Name:
Ning Ding

Title:
Chief Executive Officer, Chairman and Director

[Signature Page to the Request for Acceleration
of Effectiveness]

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ZJK Industrial Co., Ltd.

September 25, 2024

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    Re:
    ZJK Industrial Co., Ltd.

    Registration Statement on Form F-1, as amended

    Initially Filed on June 21, 2024

    File No.: 333-280371

Ladies and Gentlemen:

Pursuant to Rule 461 under the
Securities Act of 1933, as amended (the “Act”), we, Cathay Securities, Inc., as the representative of the several underwriters,
hereby join in the request by ZJK Industrial Co., Ltd. that the effective date of the above-referenced registration statement be accelerated
so that it will be declared effective at 4:00 p.m., Eastern Time, on September 27, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 under
the Act, we, as the representative of the several underwriters, wish to advise you that we have distributed to each underwriter and
dealer who is reasonably anticipated to participate in the distribution of the security to be offered a sufficient number of copies
of the preliminary prospectus dated August 20, 2024 as it appears to be reasonable to secure their adequate distribution.

We, the undersigned, as the
representative of the several underwriters, confirm that we have complied and will continue to comply with, and we have been
informed or will be informed by the participating underwriters and dealers that they have complied or will comply with, Rule 15c2-8
promulgated under the Securities Exchange Act of 1934, as amended.

Very truly yours,

Cathay Securities, Inc.

    By:
    /s/ Xiaoyu Li

    Name:
    Xiaoyu Li

    Title:
    Chief Executive Officer

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ZJK INDUSTRIAL CO., LTD.

August 1, 2024

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: ZJK Industrial Co., Ltd.

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

Filed July 24, 2024

File No. 333-280371

Dear Ms. Sidwell:

This letter is in response to the
letter dated July 29, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”). The Amended No. 2 to the Registration
Statement on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

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

Related Party Transactions, page 137

 1. We note that you have listed transactions for the fiscal years ended December 31, 2023 and 2022. Please
revise to provide the information required for the period since the beginning of your preceding three financial years up to the date of
the document. Refer to Item 7.B of Form 20-F.

Response: In response to the
Staff’s comment, we respectfully advise that we have revised the tables of related party balances and transactions on page 137,
138 and 139 of the Amended Registration Statement to provide the information required for the period since the beginning of our preceding
three financial years up to the date of the document.

We appreciate the assistance the
Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

Sarah
Sidwell

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities and Exchange Commission

August 1, 2024

Page
2 of 2

    By:
    /s/Kai Huang

    Kai Huang

    Chief Financial Officer

    Jinhua (Anna) Wang, Esq.

    Robinson & Cole LLP

[signature page to the SEC response letter]

July 29, 2024
Kai Huang
Chief Financial Officer
ZJK Industrial Co., Ltd.
No.8, Jingqiang Road, 138 Industrial Zone
Xiuxin Community, Kengzi Town
Pingshan New Area
Shenzhen, PRC
Re:ZJK Industrial Co., Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed July 24, 2024
File No. 333-280371
Dear Kai Huang:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our July 10, 2024 letter.
Amendment No. 1 to Registration Statement on Form F-1
Related Party Transactions, page 137
1.We note that you have listed transactions for the fiscal years ended December 31, 2023
and 2022. Please revise to provide the information required for the period since the
beginning of your preceding three financial years up to the date of the document. Refer to
Item 7.B of Form 20-F.

July 29, 2024
Page 2
            Please contact Beverly Singleton at 202-551-3328 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Sarah Sidwell at 202-551-4733 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Anna Wang

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ZJK INDUSTRIAL CO., LTD.

July 24, 2024

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: ZJK Industrial Co., Ltd.

Registration Statement on Form F-1

Filed June 20, 2024

File No. 333-280371

Dear Ms. Sidwell:

This letter is in response to
the letter dated July 10, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”). The First Amendment to Registration
Statement on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Registration Statement on Form F-1

Cover Page

 1. Please revise to state the number of shares of ordinary shares to be offered. Refer to Item 501(b)(2)
of Regulation S-K and Securities Act Rules C&DI 227.02.

Response: In response to the
Staff’s comment, we respectfully advise that we have revised to state the number of shares of ordinary shares to be offered throughout
the Amended Registration Statement.

Capitalization, page 77

 2. Please expand the tabular description of ordinary shares to disclose the number of shares issued and outstanding
as adjusted for the IPO, and as further adjusted to give effect to the full exercise of the over-allotment option. In addition, please
expand the capitalization table to include your outstanding amount of short-term bank borrowings and other long-term debts, current and
non-current as shown in the audited balance sheet on page F-3 and in the table of contractual obligations on page 85.

 Response: In response to the
Staff’s comment, we respectfully advise that we have revised the Capitalization table on page 77 of the Amended Registration Statement.

Sarah
Sidwell

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities and Exchange Commission

July 24, 2024

Page
2 of 3

Experts, page 162

 3. Please expand to separately discuss the consolidated financial statements of the Registrant, ZJK Industrial
Co., Ltd., and those of PSM-ZJK Fasteners (Shenzhen) Co., Ltd. for which TPS Thayer, LLC has audited both entities. Also, similar to the
consent provided at Exhibit 23.1 pertaining to the Registrant, provide a consent from TPS Thayer, LLC as pertaining to the audited financial
statements of PSM-ZJK Fasteners (Shenzhen) Co., Ltd. and to them as an expert.

 Response: In response to the
Staff’s comment, we respectfully advise that we have revised page 162 of the Amended Registration Statement and filed the consent
from TPS Thayer, LLC to the audited financial statements of PSM-ZJK Fasteners (Shenzhen) Co., Ltd. as Exhibit 23.2 of the Amended Registration
Statement.

Exhibits

 4. Please file the employment agreements between the Company and the executive officers dated May 21, 2024
as exhibits to your registration statement.

Response: In response to the
Staff’s comment, we respectfully advise that we have filed the employment agreements between the Company and the executive officers
dated May 21, 2024 as Exhibits 10.14 and 10.15 of the Amended Registration Statement.

We appreciate the assistance the
Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

Sarah
Sidwell

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities and Exchange Commission

July 24, 2024

Page
3 of 3

  By:
  /s/Kai Huang

  Kai Huang

  Chief Financial Officer

  Jinhua (Anna) Wang, Esq.

  Robinson & Cole LLP

[signature page to the SEC response letter]

July 10, 2024
Kai Huang
Chief Financial Officer
ZJK Industrial Co., Ltd.
No.8, Jingqiang Road, 138 Industrial Zone
Xiuxin Community, Kengzi Town
Pingshan New Area
Shenzhen, PRC
Re:ZJK Industrial Co., Ltd.
Registration Statement on Form F-1
Filed June 20, 2024
File No. 333-280371
Dear Kai Huang:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1
Cover Page
1.Please revise to state the number of shares of ordinary shares to be offered. Refer to Item
501(b)(2) of Regulation S-K and Securities Act Rules C&DI 227.02.
Capitalization, page 77
2.Please expand the tabular description of ordinary shares to disclose the number of shares
issued and outstanding as adjusted for the IPO, and as further adjusted to give effect to the
full exercise of the over-allotment option. In addition, please expand the capitalization
table to include your outstanding amount of short-term bank borrowings and other long-
term debts, current and non-current as shown in the audited balance sheet on page F-3 and
in the table of contractual obligations on page 85.

July 10, 2024
Page 2
Experts, page 162
3.Please expand to separately discuss the consolidated financial statements of the
Registrant, ZJK Industrial Co., Ltd., and those of PSM-ZJK Fasteners (Shenzhen) Co.,
Ltd. for which TPS Thayer, LLC has audited both entities. Also, similar to the consent
provided at Exhibit 23.1 pertaining to the Registrant, provide a consent from TPS Thayer,
LLC as pertaining to the audited financial statements of PSM-ZJK Fasteners (Shenzhen)
Co., Ltd. and to them as an expert.

Exhibits
4.Please file the employment agreements between the the Company and the executive
officers dated May 21, 2024 as exhibits to your registration statement.
            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 Beverly Singleton at 202-551-3328 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Sarah Sidwell at 202-551-4733 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Anna Wang

CORRESP
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ZJK INDUSTRIAL CO., LTD.

June 20, 2024

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: ZJK
                                            Industrial Co., Ltd.

    Amended
                                            Draft Registration Statement on Form F-1

    Filed
                                            January 19, 2024

    File
                                            No. 377-06892

Dear Ms. Sidwell:

This letter is in response to the
letter dated February 1, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”). The Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Draft Registration Statement on Form F-1 submitted
on January 19, 2024

General

 1. We note your response to prior comment 15 and reissue. Given the Chinese government’s significant
oversight and discretion over the conduct and operations of your business, please revise to describe any material impact that intervention,
influence, or control by the Chinese government has or may have on your business or on the value of your securities. Highlight separately
the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material change in
your operations and/or the value of your securities. 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. We remind you that, pursuant to federal
securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) 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.”

Response: In response to the
comment, the Registration Statement has been revised at pages 46 and 47.

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    2 of 4

Notice to Foreign Investors, page 163

 2. We note that you have removed the “Notice to Foreign Investors” disclosure.
Please advise on why this disclosure was removed from the registration statement.

Response: The section of “Notice
to Foreign Investors” was removed because the section of “Selling Restrictions” on page 163 includes general disclosures
regarding selling restrictions in any jurisdiction other than in the United States on offers and sales in or from any country or jurisdiction
except in compliance with any applicable rules and regulations of any such country or jurisdiction.

Index to Financial Statements, page F-1

 3. We
                                            note your December 31, 2022 audited financial statements are older than 12 months at the
                                            date of this amended registration statement. Please be advised that since this is an initial
                                            public offering of your ordinary shares, you are required to provide updated annual financial
                                            statements and related disclosures pursuant to Item 8.A.4 of Form 20-F, or if applicable,
                                            you should provide the representations required by Instruction 2 to Item 8.A.4 in an exhibit
                                            to the filing.

Response:
In response to the comment, audited financial statements as of December 31, 2023 are included in the Registration Statement being
filed as of the date hereof.

Note
5. Long-Term Investment, page F-51

 4. We
                                            note your response to prior comment 31 that PSM-ZJK Fasteners (Shenzhen) Co., Ltd. (“PSM-ZJK”)
                                            met the significance test at the 33% level and that you have included unaudited financial
                                            statements of PSM-ZJK for the years ended December 31, 2021 and 2022 at Exhibit 99.5. Pursuant
                                            to the analogous requirements of Rule 3-09(b) of Regulation S-X a full set of audited financial
                                            statements should be filed. In this regard, a full set of audited financial statements should
                                            be provided covering each year in which PSM-ZJK met the significance test at the 20% and
                                            above level, including an auditors report and financial statement footnotes. Please revise
                                            the financial statements at Exhibit 99.5 to comply with the requirements accordingly.

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    3 of 4

Response: In response to the
comment, the financial statements of PSM-ZJK have been revised to comply with the requirements of Rule 3-09(b) of Regulation S-X, and
re-filed as Exhibit 99.5 to the Registration Statement being filed as of the date hereof.

Exhibits

 5. Please file material contracts required by Item 601(b)(10) of Regulation S-K as
exhibits to your registration statement. In this regard, we note references to your lock-up agreements and supply agreements.

Response: In response to the comment, the Company respectfully advises the Staff that
we have filed the supply agreements and other material contracts as exhibits to the Registration Statement. We have noted in the exhibit
table that certain exhibits will be filed via amendment to the Registration Statement.

We appreciate the assistance the
Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

    Sarah
    Sidwell

    Division
    of Corporation Finance

    Office
    of Manufacturing

    U.S.
    Securities and Exchange Commission

    June 20, 2024

    Page
    4 of 4

    By:
    /s/Kai Huang

    Kai Huang

    Chief Financial Officer

cc:
Jinhua (Anna) Wang, Esq.

Robinson & Cole LLP

[signature page to the SEC response letter]

United States securities and exchange commission logo
February 1, 2024
Kai Huang
Chief Financial Officer
ZJK Industrial Co., Ltd.
No.8, Jingqiang Road, 138 Industrial Zone
Xiuxin Community, Kengzi Town
Pingshan New Area
Shenzhen, PRC
Re:ZJK Industrial Co., Ltd.
Amended Draft Registration Statement on Form F-1
Filed January 19, 2024
File No. 377-06892
Dear Kai Huang:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our October 23, 2023 letter.
Draft Registration Statement on Form F-1 submitted on January 19, 2024
General
1.We note your response to prior comment 15 and reissue. Given the Chinese government’s
significant oversight and discretion over the conduct and operations of your business,
please revise to describe any material impact that intervention, influence, or control by the
Chinese government has or may have on your business or on the value of your securities.
Highlight separately the risk that the Chinese government may intervene or influence your
operations at any time, which could result in a material change in your operations and/or
the value of your securities. 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

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 February 1, 2024 Page 2
 FirstName LastName
Kai Huang
ZJK Industrial Co., Ltd.
February 1, 2024
Page 2
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. We remind you that, pursuant to federal securities rules, the term
“control” (including the terms “controlling,” “controlled by,” and “under common control
with”) 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.”
Notice to Foreign Investors, page 163
2.We note that you have removed the "Notice to Foreign Investors" disclosure. Please
advise on why this disclosure was removed from the registration statement.
Index to Financial Statements, page F-1
3.We note your December 31, 2022 audited financial statements are older than 12 months at
the date of this amended registration statement. Please be advised that since this is an
initial public offering of your ordinary shares, you are required to provide updated annual
financial statements and related disclosures pursuant to Item 8.A.4 of Form 20-F, or if
applicable, you should provide the representations required by Instruction 2 to Item 8.A.4
in an exhibit to the filing.

Note 5. Long-Term Investment, page F-51
4.We note your response to prior comment 31 that PSM-ZJK Fasteners (Shenzhen) Co.,
Ltd. ("PSM-ZJK") met the significance test at the 33% level and that you have included
unaudited financial statements of PSM-ZJK for the years ended December 31, 2021 and
2022 at Exhibit 99.5. Pursuant to the analogous requirements of Rule 3-09(b) of
Regulation S-X a full set of audited financial statements should be filed. In this regard, a
full set of audited financial statements should be provided covering each year in which
PSM-ZJK met the significance test at the 20% and above level, including an auditors
report and financial statement footnotes. Please revise the financial statements at Exhibit
99.5 to comply with the requirements accordingly.

Exhibits
5.Please file material contracts required by Item 601(b)(10) of Regulation S-K as exhibits to
your registration statement. In this regard, we note references to your lock-up agreements
and supply agreements.

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 February 1, 2024 Page 3
 FirstName LastName
Kai Huang
ZJK Industrial Co., Ltd.
February 1, 2024
Page 3
            Please contact Beverly Singleton at 202-551-3328 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Sarah Sidwell at 202-551-4733 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Anna Wang

CORRESP
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ZJK INDUSTRIAL CO., LTD.

January 18, 2024

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: ZJK Industrial Co., Ltd.

  Draft Registration Statement on Form F-1

  Filed September 26, 2023

  File No. 377-06892

Dear Ms. Sidwell:

This letter is in response
to the letter dated October 23, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to ZJK Industrial Co., Ltd. (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. The amendment
to Draft Registration Statement on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Draft Registration Statement on Form F-1

General

 1. Please note the financial statement updating requirements as set forth in Item 8.A.5 of the Form
20-F. In this regard, the next submission should also include unaudited interim financial statements and related financial information
for the six months ended June 30, 2023 and 2022.

Response:
Pursuant to the comment, we have included the unaudited interim financial statements and related financial information for
the six months ended June 30, 2023 and 2022  in the Registration Statement.

 2. Please supplementary 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 communication.

Response:
Neither the Company nor anyone authorized by the Company has presented any written communications, as
defined in Rule 405 under the Securities Act, to potential investors in reliance on Section 5(d) of the Securities Act. To the
extent that any such written communications are later presented to potential investors, the Company will supplementally provide
copies to the Staff.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 2 of 13

 3. Please disclose whether and how your business segments, products, lines of service, projects, or
operations are materially impacted by supply chain disruptions, especially in light of in light of the effectiveness of the Uyghur
Forced Labor Protection Act (the “UFLPA”). For example, discuss whether you have or expect to:

 · suspend the production, purchase, sale or maintenance of certain items due to a lack of raw materials,
parts, or equipment; inventory shortages; closed factories or stores; reduced headcount; or delayed projects;

 · experience labor shortages that impact your business;

 · experience cybersecurity attacks in your supply chain;

 · experience higher costs due to constrained capacity or increased commodity prices or challenges
sourcing materials (e.g. steel, lithium, nickel, manganese, beryllium, copper, gold or other raw material sourced from Western
China);

 · experience surges or declines in consumer demand for which you are unable to adequately adjust
your supply;

 · be unable to supply products at competitive prices or at all due to export restrictions, sanctions,
tariffs, trade barriers, or political or trade tensions among countries; or

 · be exposed to supply chain risk in light of the effectiveness of the UFLPA and/or related geopolitical
tension.

  Explain whether and how you have undertaken efforts to mitigate the impact and where possible quantify
the impact to your business.

Response: Pursuant to the comment,
we have revised the disclosure on page 37 of the Registration Statement.

Cover Page

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

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 3 of 13

Response: The Company respectfully
advises the Staff that we do not have a VIE structure, and we have revised the disclosure on the cover page of the Registration
Statement to include such statement.

 5. Provide a description of how cash is transferred through your organization and disclose your intentions
to distribute earnings or settle amounts owed under the VIE agreements. State whether any transfers, dividends, or distributions
have been made to date between the holding company, its subsidiaries, and consolidated VIEs, or to investors, and quantify the
amounts where applicable.

Response:
Pursuant to the comment, we have included a description of how cash is transferred through our organization and updated
the amounts of dividends and distributions made by us as of the date hereof on page 5 of the Registration
Statement.

The Company respectfully advises the Staff
that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement to include
such statement.

Commonly Used Define Terms, page 10

 6. Please consider expanding the last paragraph on page 11 to also discuss your 1:2 share split that
occurred on June 19, 2023 and how all related share information has been retroactively reflected. In this regard, we note disclosure
on page F-33 that the shares and per share information are presented on a retroactive basis for the periods presented, to reflect
the reorganization completed on March 28, 2023 and share split that occurred on June 19, 2023. This information should also be
included in a more prominent location within the filing.

Response: Pursuant to the comment,
we have revised the relevant disclosures on the cover page and page 11 of the Registration Statement.

Prospectus Summary, page 12

 7. Please clarify in the last sentence of the introductory paragraph on page 12 that the consolidated
financial statements included in the prospectus are for the years ended December 31, 2022 and 2021. Your current disclosure states
for the years ended December 31, 2021 and 2020.

Response:
Pursuant to the comment, we have revised the disclosure on page 12 of the Registration Statement.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 4  of 13

 8. We note that the consolidated VIEs constitute a material part of your consolidated financial statements.
Please provide in tabular form a condensed consolidating schedule that disaggregates the operations and depicts the financial position,
cash flows, and results of operations as of the same dates and for the same periods for which audited consolidated financial statements
are required. The schedule should present major line items, such as revenue and cost of goods/services, and subtotals and disaggregated
intercompany amounts, such as separate line items for intercompany receivables and investment in subsidiary. The schedule should
also disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that are the primary beneficiary of
the VIEs, and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor
to evaluate the nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts
associated with intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary, additional
disclosure about such amounts should be included in order to make the information presented not misleading.

Response: The Company respectfully
advises the Staff that it does not have a VIE structure and therefore believes that this comment is not applicable to the Registration
Statement.

 9. Disclose clearly that the company uses a structure that involves a VIE based in China and what
that entails, and provide early in the summary a diagram of the company’s corporate structure, identifying the person or
entity that owns the equity in each depicted entity. Describe all contracts and arrangements through which you claim to have economic
rights and exercise control that results in consolidation of the VIE’s operations and financial results into your financial
statements. Identify clearly the entity in which investors are purchasing their interest and the entity(ies) in which the company’s
operations are conducted. Describe the relevant contractual agreements between the entities and how this type of corporate structure
may affect investors and the value of their investment, including how and why the contractual arrangements may be less effective
than direct ownership and that the company may incur substantial costs to enforce the terms of the arrangements. Disclose the uncertainties
regarding the status of the rights of the Cayman Islands holding company with respect to its contractual arrangements with the
VIE, its founders and owners, and the challenges the company may face enforcing these contractual agreements due to legal uncertainties
and jurisdictional limits.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 5 of 13

 10. It is unclear from your disclosure whether the Cayman Islands holding company controls and receives
the economic benefits of the VIE’s business operations through contractual agreements between the VIE and your Wholly Foreign-Owned
Enterprise (WFOE) and that those agreements are designed to provide your WFOE with the power, rights, and obligations equivalent
in all material respects to those it would possess as the principal equity holder of the VIE. We also note your disclosure that
the Cayman Islands holding company is the primary beneficiary of the VIE. However, neither the investors in the holding company
nor the holding company itself have an equity ownership in, direct foreign investment in, or control of, through such ownership
or investment, the VIE. Accordingly, please refrain from implying that the contractual agreements are equivalent to equity ownership
in the business of the VIE. Any references to control or benefits that accrue to you because of the VIE should be limited to a
clear description of the conditions you have satisfied for consolidation of the VIE under U.S. GAAP. Additionally, your disclosure
should clarify that you are the primary beneficiary of the VIE for accounting purposes. Please also disclose, if true, that the
VIE agreements have not been tested in a court of law.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

Corporate Structure, page 17

 11. Please include a paragraph discussion disclosing that Zhongjinke Shenzhen is a variable interest
entity (“VIE”), and that it along with its related consolidated and unconsolidated entities, is a domestic company
incorporated in mainland China in which you do not have any equity ownership but whose financial results have been consolidated
into your consolidated financial statements based solely on contractual arrangements in accordance with U.S. GAAP. In this regard,
also disclose that as a result of your 100% indirect ownership of Zhongjinke WFOE and the contractual arrangements with the VIE,
you are regarded as the primary beneficiary of the VIE and that you treat the variable interest entity as the consolidated VIE
under U.S. GAAP, which generally refers to an entity in which you do not have any equity interest, but consolidate as you have
a controlling financial interest in that entity.

Response: The Company advises
the Staff that we do not have a VIE structure and we have revised the disclosure on the cover page of the Registration Statement
to include such statement.

 12. Refer to the diagram of your corporate legal structure on pages 18 and 92. Please disclose whom
holds the respective 49% and 51% interest in the PRC entities Zhongjinke Nanjing and PSM-ZJK. Also on page 91 regarding the discussion
of the January 10, 2023 share exchange agreement with Ms. Yingjing Deng, describe the ownership structure between Galaxy Exploration
and Zhongjinke Shenzhen prior to and after this agreement, as it is not clear as to the ownership interest or common control interests
of Ms. Deng in either company before the share exchange agreement with Zhongjinke HK.

Sarah Sidwell

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

January 18, 2024

 Page 6 of 13

Response: We respectfully advise the Staff that we have revised the disclosures on page
19, page 97 and page 98 of the Registration Statement.

Summary Consolidated Financial and Operating
Data, page 32

 13. We note from the introductory paragraph that you are presenting summary consolidated balance sheet
data as of December 31, 2022 and 2021; however, we are not able to locate this balance sheet information. Please revise accordingly
to present the data.

Response: In
response to the Staff’s comment, we respectfully advise the Staff that we revised the disclosure on page 34.

Risk Factors, page 33

 14. Revise your risk factors to acknowledge that if the PRC government determines that the contractual
arrangements constituting part of the VIE structure do not comply with PRC regulations, or if these regulations change or are interpreted
differently in the future, the securities you are registering may decline in value or become worthless if the determinations, changes,
or interpretations result in your inability to assert contractual control over the assets of your PRC subsidiaries or the VIEs
that conduct all or substantially all of your operations.

Response: The Company respectfully
advises the Staff that we do not have a VIE structure and therefore believes that this comment is not applicable to the Registration
Statement.

 15. Given the significant oversight and discretion of the government of the People’s Republic
of China (PRC) over the operations of your business, please describe any material impact that intervention or control by the PRC
government has or may have on your business or on the value of your securities. We remind you that, pursuant to federal securities
rules, the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) 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.”

Response: The Company

United States securities and exchange commission logo
October 23, 2023
Kai Huang
Chief Financial Officer
ZJK Industrial Co., Ltd.
No.8, Jingqiang Road, 138 Industrial Zone
Xiuxin Community, Kengzi Town
Pingshan New Area
Shenzhen, PRC
Re:ZJK Industrial Co., Ltd.
Draft Registration Statement on Form F-1
Filed September 26, 2023
File No. 377-06892
Dear Kai Huang:
            We have reviewed your draft registration statement and have the following comments.
            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 a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1
General
1.Please note the financial statement updating requirements as set forth in Item 8.A.5 of the
Form 20-F.  In this regard, the next submission should also include unaudited interim
financial statements and related financial information for the six months ended June 30,
2023 and 2022.

2.Please supplementary 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 communication.

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 October 23, 2023 Page 2
 FirstName LastName
Kai Huang
ZJK Industrial Co., Ltd.
October 23, 2023
Page 2
3. Please disclose whether and how your business segments, products, lines of service,
projects, or operations are materially impacted by supply chain disruptions, especially in
light of in light of the effectiveness of the Uyghur Forced Labor Protection Act (the
"UFLPA"). For example, discuss whether you have or expect to:
•suspend the production, purchase, sale or maintenance of certain items due to a lack
of raw materials, parts, or equipment; inventory shortages; closed factories or stores;
reduced headcount; or delayed projects;
•experience labor shortages that impact your business;
•experience cybersecurity attacks in your supply chain;
•experience higher costs due to constrained capacity or increased commodity prices or
challenges sourcing materials (e.g. steel, lithium, nickel, manganese, beryllium,
copper, gold or other raw material sourced from Western China);
•experience surges or declines in consumer demand for which you are unable to
adequately adjust your supply;
•be unable to supply products at competitive prices or at all due to export restrictions,
sanctions, tariffs, trade barriers, or political or trade tensions among countries; or
•be exposed to supply chain risk in light of the effectiveness of the UFLPA and/or
related geopolitical tension.
Explain whether and how you have undertaken efforts to mitigate the impact and where
possible quantify the impact to your business.
Cover Page
4.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Cayman Islands holding company with operations conducted by
your subsidiaries and through contractual arrangements with a variable interest entity
(VIE) based in China and that this structure involves unique risks to investors. If true,
disclose that these contracts have not been tested in court. Explain whether the VIE
structure is used to provide investors with exposure to foreign investment in China-based
companies where Chinese law prohibits direct foreign investment in the operating
companies, and disclose that investors may never hold equity interests in the Chinese
operating company. Your disclosure should acknowledge that Chinese regulatory
authorities could disallow this structure, which would likely result in a material change in
your operations and/or a material change in the value of the securities you are registering
for sale, including that it could cause the value of such securities to significantly decline
or become worthless. Provide a cross-reference to your detailed discussion of risks facing
the company and the offering as a result of this structure.
5.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings or settle amounts owed under the VIE agreements.
State whether any transfers, dividends, or distributions have been made to date between
the holding company, its subsidiaries, and consolidated VIEs, or to investors, and quantify
the amounts where applicable.

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 October 23, 2023 Page 3
 FirstName LastName
Kai Huang
ZJK Industrial Co., Ltd.
October 23, 2023
Page 3
Commonly Used Define Terms, page 10
6.Please consider expanding the last paragraph on page 11 to also discuss your 1:2 share
split that occurred on June 19, 2023 and how all related share information has been
retroactively reflected.  In this regard, we note disclosure on page F-33 that the shares and
per share information are presented on a retroactive basis for the periods presented, to
reflect the reorganization completed on March 28, 2023 and share split that occurred on
June19, 2023.  This information should also be included in a more prominent location
within the filing.

Prospectus Summary, page 12
7.Please clarify in the last sentence of the introductory paragraph on page 12 that the
consolidated financial statements included in the prospectus are for the years ended
December 31, 2022 and 2021.  Your current disclosure states for the years ended
December 31, 2021 and 2020.

8.We note that the consolidated VIEs constitute a material part of your consolidated
financial statements. Please provide in tabular form a condensed consolidating schedule
that disaggregates the operations and depicts the financial position, cash flows, and results
of operations as of the same dates and for the same periods for which audited consolidated
financial statements are required. The schedule should present major line items, such as
revenue and cost of goods/services, and subtotals and disaggregated intercompany
amounts, such as separate line items for intercompany receivables and investment in
subsidiary. The schedule should also disaggregate the parent company, the VIEs and its
consolidated subsidiaries, the WFOEs that are the primary beneficiary of the VIEs, and an
aggregation of other entities that are consolidated. The objective of this disclosure is to
allow an investor to evaluate the nature of assets held by, and the operations of, entities
apart from the VIE, as well as the nature and amounts associated with intercompany
transactions. Any intercompany amounts should be presented on a gross basis and when
necessary, additional disclosure about such amounts should be included in order to make
the information presented not misleading.

9.Disclose clearly that the company uses a structure that involves a VIE based in China and
what that entails, and provide early in the summary a diagram of the company’s corporate
structure, identifying the person or entity that owns the equity in each depicted entity.
Describe all contracts and arrangements through which you claim to have economic rights
and exercise control that results in consolidation of the VIE’s operations and financial
results into your financial statements. Identify clearly the entity in which investors are
purchasing their interest and the entity(ies) in which the company’s operations are
conducted. Describe the relevant contractual agreements between the entities and how this
type of corporate structure may affect investors and the value of their investment,

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 October 23, 2023 Page 4
 FirstName LastNameKai Huang
ZJK Industrial Co., Ltd.
October 23, 2023
Page 4
including how and why the contractual arrangements may be less effective than direct
ownership and that the company may incur substantial costs to enforce the terms of the
arrangements. Disclose the uncertainties regarding the status of the rights of the Cayman
Islands holding company with respect to its contractual arrangements with the VIE, its
founders and owners, and the challenges the company may face enforcing these
contractual agreements due to legal uncertainties and jurisdictional limits.
10.It is unclear from your disclosure whether the Cayman Islands holding company controls
and receives the economic benefits of the VIE’s business operations through contractual
agreements between the VIE and your Wholly Foreign-Owned Enterprise (WFOE) and
that those agreements are designed to provide your WFOE with the power, rights, and
obligations equivalent in all material respects to those it would possess as the principal
equity holder of the VIE. We also note your disclosure that the Cayman Islands holding
company is the primary beneficiary of the VIE. However, neither the investors in the
holding company nor the holding company itself have an equity ownership in, direct
foreign investment in, or control of, through such ownership or investment, the VIE.
Accordingly, please refrain from implying that the contractual agreements are equivalent
to equity ownership in the business of the VIE. Any references to control or benefits that
accrue to you because of the VIE should be limited to a clear description of the conditions
you have satisfied for consolidation of the VIE under U.S. GAAP. Additionally, your
disclosure should clarify that you are the primary beneficiary of the VIE for accounting
purposes. Please also disclose, if true, that the VIE agreements have not been tested in a
court of law.
Corporate Structure, page 17
11.Please include a paragraph discussion disclosing that Zhongjinke Shenzhen is a variable
interest entity ("VIE"), and that it along with its related consolidated and unconsolidated
entities, is a domestic company incorporated in mainland China in which you do not have
any equity ownership but whose financial results have been consolidated into your
consolidated financial statements based solely on contractual arrangements in accordance
with U.S. GAAP.  In this regard, also disclose that as a result of your 100% indirect
ownership of Zhongjinke WFOE and the contractual arrangements with the VIE, you are
regarded as the primary beneficiary of the VIE and that you treat the variable interest
entity as the consolidated VIE under U.S. GAAP, which generally refers to an entity in
which you do not have any equity interest, but consolidate as you have a controlling
financial interest in that entity.

12.Refer to the diagram of your corporate legal structure on pages 18 and 92.  Please disclose
whom holds the respective 49% and 51% interest in the PRC entities Zhongjinke Nanjing
and PSM-ZJK.  Also on page 91 regarding the discussion of the January 10, 2023 share
exchange agreement with Ms. Yingjing Deng, describe the ownership structure between
Galaxy Exploration and Zhongjinke Shenzhen prior to and after this agreement, as it is not

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 October 23, 2023 Page 5
 FirstName LastNameKai Huang
ZJK Industrial Co., Ltd.
October 23, 2023
Page 5
clear as to the ownership interest or common control interests of Ms. Deng in either
company before the share exchange agreement with Zhongjinke HK.

Summary Consolidated Financial and Operating Data, page 32
13.We note from the introductory paragraph that you are presenting summary consolidated
balance sheet data as of December 31, 2022 and 2021; however, we are not able to locate
this balance sheet information.  Please revise accordingly to present the data.

Risk Factors, page 33
14.Revise your risk factors to acknowledge that if the PRC government determines that the
contractual arrangements constituting part of the VIE structure do not comply with PRC
regulations, or if these regulations change or are interpreted differently in the future, the
securities you are registering may decline in value or become worthless if the
determinations, changes, or interpretations result in your inability to assert contractual
control over the assets of your PRC subsidiaries or the VIEs that conduct all or
substantially all of your operations.
15.Given the significant oversight and discretion of the government of the People’s Republic
of China (PRC) over the operations of your business, please describe any material impact
that intervention or control by the PRC government has or may have on your business or
on the value of your securities.  We remind you that, pursuant to federal securities rules,
the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) 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.”
16.Please describe the extent and nature of the role of the board of directors in overseeing
cybersecurity risks, including in connection with the company’s supply
chain/suppliers/service providers.
Any disruption in the supply chain of raw materials and our products could adversely impact our
ability to produce and deliver products., page 34
17.We note your risk factor on page 34 regarding supply chain issues.  Please discuss
whether supply chain disruptions materially affect your outlook or business goals. Specify
whether these challenges have materially impacted your results of operations or capital
resources and quantify, to the extent possible, how your sales, profits, and/or liquidity
have been impacted.
18.We note your risk factor on page 34 indicating that price increases could affect your
prices for your raw materials and your products. Please update this risk factor in future
filings if recent inflationary pressures have materially impacted your operations. In this
regard, identify the types of inflationary pressures you are facing and how your business

 FirstName LastNameKai Huang
 Comapany NameZJK Industrial Co., Ltd.
 October 23, 2023 Page 6
 FirstName LastNameKai Huang
ZJK Industrial Co., Ltd.
October 23, 2023
Page 6
has been affected.
Risks Related to This Offering and the Ordinary Shares
If we fail to establish and maintain proper internal financial reporting controls, our ability to
produce accurate financial...be impaired., page 70
19.In the first sentence of the second paragraph, please update this disclosure as of the year
ended December 31, 2022.  Your current disclosure appears to pertain to the prior year
ended December 31, 2021.  Also, in the third paragraph, clarify that you will be required
to include a report from management on your internal control over financial reporting in
your annual report on Form 20-F beginning with the year ended December 31, 2024.
Your current disclosure states the fiscal year ending December 31, 2022.  In this regard,
pursuant to Item 308 of Regulation S-K, such management's report on your internal
control over financial reporting will be required beginning with your second annual report
on Form 20-F after becoming a public company.

Capitalization, page 77
20.We note disclosure on page F-31 that your other long-term debts include your factory
mortgage loan and commercial vehicle mortgage loan.  Please expand the table to also
include both your short-term bank borrowings and the other long-term indebtedness.  The
total capitalization amount should be reflective of your total debt and equity.

Dilution, page 78
21.Refer to the third sentence of the first paragraph where you disclose pro forma net tangible
book value per Ordinary Share is cal