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                            October 16, 2023

       Huiping Yan
       Chief Financial Officer
       ZTO Express (Cayman) Inc.
       Building One, No. 1685 Huazhi Road
       Qingpu District, Shanghai, 201708
       People   s Republic of China

                                                        Re: ZTO Express 
(Cayman) Inc.
                                                            Form 20-F for the 
Fiscal Year ended December 31, 2022
                                                            Filed April 20, 
2023
                                                            Response letter 
dated September 27, 2023
                                                            File No. 001-37922

       Dear Huiping Yan:

              We have reviewed your September 27, 2023 response to our comment 
letter and have the
       following comment(s).

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in 
your response.

               After reviewing your response to this letter, we may have 
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in 
our September 13, 2023
       letter.

       Form 20-F for the Fiscal Year ended December 31, 2022

       Condensed Consolidating Financial Information of ZTO Express (Cayman) 
Inc., page 13

   1.                                                   We note your response 
to prior comment one explaining that your subsidiaries leased
                                                        land, buildings, 
equipment and trucks to the VIE's and their subsidiaries, which recorded
                                                        the rental fees in all 
cases as cost of revenues, while your subsidiaries recorded the
                                                        corresponding rental 
income as either revenues or other operating income "...based on the
                                                        subsidiaries    primary 
business operations." Please address the following points:

                                                              Describe the 
accounting policies that you applied in determining whether rental
                                                            income would be 
reported as revenue or as other operating income, including how the
                                                            nature of the VIE's 
and their subsidiaries primary business operations were evaluated
 Huiping Yan
ZTO Express (Cayman) Inc.
October 16, 2023
Page 2
              and considered in accounting for the transactions.

                Tell us how the leased land, buildings, equipment and trucks 
are used to generate
              revenues by your VIE's.

                Indicate the extent to which the leased property is 
attributable to selling, general and
              administrative purposes, and separately to the generate of 
revenues, and explain to us
              the basis for your determinations in this regard.

         Given your statement that all intercompany transactions were fully 
eliminated with no
         impact on revenue, cost of revenue, or gross profit, we understand 
that the elimination for
         cost of revenues in excess of the elimination for revenues equates to 
the revenues that
         were booked by your subsidiaries as other operating income.

         Please confirm if this is the case or provide any additional details 
necessary to understand
         the disparity with the eliminations in 2022.
2.       We understand from your response to prior comment one that all 
internal rental income
         from the lease arrangements for 2020 and 2021 is reported as revenue 
in the schedules on
         page 18 and therefore the eliminations for revenues and cost of 
revenues are equal for
         these earlier periods. Tell us the amounts that were initially 
reported as other operating
         income for 2020 and 2021 and explain how your formulated your view on 
materiality.

       Please contact Robert Babula, Staff Accountant, at (202) 551-3339 or Gus 
Rodriguez,
Staff Accountant, at (202) 551-3752 if you have questions regarding comments on 
the financial
statements and related matters.



FirstName LastNameHuiping Yan                                   Sincerely,
Comapany NameZTO Express (Cayman) Inc.
                                                                Division of 
Corporation Finance
October 16, 2023 Page 2                                         Office of 
Energy & Transportation
FirstName LastName