TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 4, 2023 David Leung Chief Executive Officer Euro Tech Holdings Company Limited Unit D, 18/F, Gee Chang Hong Centre 65 Wong Chuk Hang Road Hong Kong Re: Euro Tech Holdings Company Limited Form 20-F for the Fiscal Year Ended December 31, 2022 Response dated July 27, 2023 File No. 000-22113 Dear David Leung: We have reviewed your July 27, 2023 response to our comment letter 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 these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 General 1. We note your statement that you are "not owned or controlled by any governmental entity in any jurisdiction" in connection with your required submission under paragraph (a). Please supplementally describe the materials that were reviewed and tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. In your response, please provide a similarly detailed discussion of the materials reviewed and legal opinions or third party certifications relied upon in connection with the required disclosures under paragraphs (b)(2) and (3). 2. In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party. For David Leung Euro Tech Holdings Company Limited August 4, 2023 Page 2 instance, please tell us how the board members current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party certifications such as affidavits as the basis for your disclosure. 3. We note that your proposed disclosures pursuant to Items 16I(b)(2), (b)(3) and (b)(5) use the term the Company. It is unclear from the context of these disclosures whether this term is meant to encompass you and all of your consolidated foreign operating entities or whether in some instances these terms refer solely to Euro Tech Holdings Company Limited as you only identify your subsidiaries pursuant to Item 16I(b)(4). Please note that Item 16I(b) requires that you provide each disclosure for yourself and your consolidated foreign operating entities, including variable interest entities or similar structures. To clarify this matter, please provide the information required by each subsection of Item 16I(b) for you and all of your consolidated foreign operating entities. Please contact Tyler Howes at 202-551-3370 or Christopher Dunham at 202-551-3783 with any questions. Sincerely, FirstName LastNameDavid Leung Division of Corporation Finance Comapany NameEuro Tech Holdings Company Limited Disclosure Review Program August 4, 2023 Page 2 cc: Richard Friedman, Esq. FirstName LastName