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                             July 22, 2022

       Huisen Wang
       Chief Executive Officer
       Huadi International Group Co., Ltd.
       No. 1688 Tianzhong Street, Longwan District
       Wenzhou, Zhejiang Province
       People   s Republic of China 325025

                                                        Re: Huadi International 
Group Co., Ltd.
                                                            Registration 
Statement on Form F-3
                                                            Filed on June 28, 
2022
                                                            File No. 333-265882

       Dear Mr. 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.

       Form F-3 filed June 28, 2022

       Cover Page

   1.                                                   On your cover page, 
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. Throughout your prospectus, refrain from using terms
                                                        such as    we    or    
our    when describing activities or functions of a PRC-based subsidiary.
                                                        For example, disclose, 
if true, that your subsidiaries conduct operations in China and that
                                                        the holding company 
does not conduct operations. Disclose clearly the entity (including
                                                        the domicile) in which 
investors are purchasing an interest.
 Huisen Wang
Huadi International Group Co., Ltd.
July 22, 2022
Page 2
2.       On your cover page, provide a description of how cash is transferred 
through your
         organization and disclose your intentions to distribute earnings or 
settle amounts owed
         under your agreements. 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.
        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 Bradley Ecker at (202) 551-4985 or Asia Timmons-Pierce at 
(202) 551-
3754 with any questions.



FirstName LastNameHuisen Wang                                 Sincerely,
Comapany NameHuadi International Group Co., Ltd.
                                                              Division of 
Corporation Finance
July 22, 2022 Page 2                                          Office of 
Manufacturing
FirstName LastName