United States securities and exchange commission logo




                                                                                
                              May 8, 2024

       Lin Yang
       Chief Financial Officer
       Universe Pharmaceuticals INC
       265 Jingjiu Avenue
       Jinggangshan Economic and Technological Development Zone
       Ji   an, Jiangxi, China 343100

                                                        Re: Universe 
Pharmaceuticals INC
                                                            Registration 
Statement on Form F-1
                                                            Filed April 24, 
2024
                                                            File No. 333-278914

       Dear Lin Yang:

              We have conducted a limited review of your registration statement 
and have the
       following comments.

              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 here, and 
elsewhere, to disclose that the Accelerating Holding Foreign
                                                        Companies Accountable 
Act was signed into law as part of the fiscal year 2023 omnibus
                                                        spending legislation on 
December 29, 2022.
   2.                                                   Please revise the cover 
page to disclose the termination date of the offering. See
                                                        Item 501(b)(8)(iii) of 
Regulation S-K.
               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
 Lin Yang
Universe Pharmaceuticals INC
May 8, 2024
Page 2

time for us to review any amendment prior to the requested effective date of 
the registration
statement.

       Please contact Jimmy McNamara at 202-551-7349 or Chris Edwards at 
202-551-6761
with any other questions.



                                                             Sincerely,
FirstName LastNameLin Yang
                                                             Division of 
Corporation Finance
Comapany NameUniverse Pharmaceuticals INC
                                                             Office of Life 
Sciences
May 8, 2024 Page 2
cc:       Ying Li
FirstName LastName