United States securities and exchange commission logo




                                                                                
                      January 25, 2023

       Di Chen
       Corporate Secretary
       ZK International Group Co., Ltd.
       No. 678 Dingxiang Road, Binhai Industrial Park
       Economic & Technology Development Zone
       Wenzhou, Zhejiang Province
       People   s Republic of China 325025

                                                        Re: ZK International 
Group Co., Ltd.
                                                            Form 20-F for the 
Fiscal Year Ended September 30, 2021
                                                            Filed January 28, 
2022
                                                            File No. 001-38146

       Dear Di Chen:

              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 Manufacturing