United States securities and exchange commission logo
December 9, 2022
Bin Zhou
Chief Executive Officer
Planet Green Holdings Corp.
36-10 Union St., 2nd Floor
Flushing, NY 11345
Re: Planet Green
Holdings Corp.
Amendment No. 3 to
Registration Statement on Form S-3
Filed December 5,
2022
File No. 333-259611
Dear Bin Zhou:
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 29, 2022, letter.
Amendment No. 3 to Form S-3
General
1. Despite your response
to prior comment seven, disclosure regarding regulatory
permissions or
approvals required to operate your business still appears to be lacking.
Please add the
following disclosure:
Disclose each
permission or approval that you, your subsidiaries, your WFOE, and/or
your VIEs are
required to obtain from Chinese authorities (including Hong Kong
authorities) to
operate your business.
State
affirmatively whether you have received all requisite operating permissions or
Bin Zhou
Planet Green Holdings Corp.
December 9, 2022
Page 2
approvals and whether any permissions or approvals have been
denied.
Describe the consequences to you and your investors if you,
your subsidiaries,
WFOE, or the VIEs: (i) do not receive or maintain such operating
permissions or
approvals, (ii) inadvertently conclude that such operating
permissions or approvals
are not required, or (iii) applicable laws, regulations, or
interpretations change and
you are required to obtain such operating permissions or
approvals in the future.
If your revised disclosure indicates no operating permissions
or approvals are
required from Chinese authorities (including Hong Kong
authorities), then
additionally disclose how you determined this. If you relied on
counsel, identify
counsel and file an exhibit. If you did not consult counsel,
provide an explanation as
to why you did not consult counsel. Please expand or revise
related risk factors as
appropriate.
About this Prospectus
Financial Information Related to the VIEs, page 9
FirstName LastNameBin Zhou
2. We note your revisions in response to prior comment four, and reissue it
in part. Please
Comapany NamePlanet
revise Green Holdings
your consolidating Corp.
schedules to present information for the WFOE
as primary
beneficiary
December 9, 2022 in a separate
Page 2 column.
FirstName LastName
Bin Zhou
FirstName LastNameBin Zhou
Planet Green Holdings Corp.
Comapany9,
December NamePlanet
2022 Green Holdings Corp.
December
Page 3 9, 2022 Page 3
FirstName LastName
Please contact Jennifer Angelini at 202-551-3047 or Jay Ingram at
202-551-3397 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
cc: Steven Glauberman