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                            October 27, 2022

       Xiangyu Pei
       Interim Chief Financial Officer
       CBAK Energy Technology, Inc.
       CBAK Industrial Park, Meigui Street
       Huayuankou Economic Zone
       Dalian City, Liaoning Province
       People's Republic of China, 116450

                                                        Re: CBAK Energy
Technology, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Filed April 15,
2022
                                                            File No. 001-32898

       Dear Xiangyu Pei:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 10-K for the Year Ended December 31, 2021

       Disclosures Related to Our China-Based Operations, page iii

   1.                                                   Please enhance your
disclosure to also disclose whether you have been or expect to be
                                                        identified by the
Commission under the Holding Foreign Companies Accountable Act.
   2.                                                   Please disclose the
risks that your corporate structure and being based in or having the
                                                        majority of the company
  s operations in China poses to investors. In particular, describe
                                                        the significant
regulatory, liquidity, and enforcement risks with cross-references to the
                                                        more detailed
discussion of these risks in the prospectus. For example, specifically
                                                        discuss risks arising
from the legal system in China, including risks and uncertainties
                                                        regarding the
enforcement of laws and that rules and regulations in China can change
                                                        quickly with little
advance notice; and the risk that the Chinese government may intervene
 Xiangyu Pei
FirstName LastNameXiangyu   Pei
CBAK Energy   Technology, Inc.
Comapany
October 27,NameCBAK
            2022       Energy Technology, Inc.
October
Page 2 27, 2022 Page 2
FirstName LastName
         or influence your operations at any time, or may exert more control
over offerings
         conducted overseas and/or foreign investment in China-based issuers,
which could result
         in a material change in your operations and/or the value of your
securities. Acknowledge
         any risks that any actions by the Chinese government to exert more
oversight and control
         over offerings that are conducted overseas and/or foreign investment
in China-based
         issuers could significantly limit or completely hinder your ability to
offer or continue to
         offer securities to investors and cause the value of such securities
to significantly decline
         or be worthless.
3.       Disclose each permission or approval that you or your subsidiaries are
required to obtain
         from Chinese authorities to operate your business and to offer the
securities being
         registered to foreign investors. State whether you or your
subsidiaries are covered by
         permissions requirements from the China Securities Regulatory
Commission (CSRC),
         Cyberspace Administration of China (CAC) or any other governmental
agency that is
         required to approve your operations, and state affirmatively whether
you have received all
         requisite permissions or approvals and whether any permissions or
approvals have been
         denied. Please also describe the consequences to you and your
investors if you or your
         subsidiaries: (i) do not receive or maintain such permissions or
approvals, (ii)
         inadvertently conclude that such permissions or approvals are not
required, or (iii)
         applicable laws, regulations, or interpretations change and you are
required to obtain such
         permissions or approvals in the future.
4.       Please enhance your disclosure to provide a clear description of how
cash is transferred
         through your organization. Quantify any cash flows and transfers of
other assets by type
         that have occurred between the holding company and its subsidiaries,
and direction of
         transfer. Quantify any dividends or distributions that a subsidiary
has made to the holding
         company and which entity made such transfer, and their tax
consequences. Similarly
         quantify dividends or distributions made to U.S. investors, the
source, and their tax
         consequences. Your disclosure should make clear if no transfers,
dividends, or
         distributions have been made to date. Describe any restrictions on
foreign exchange and
         your ability to transfer cash between entities, across borders, and to
U.S. investors.
          Describe any restrictions and limitations on your ability to
distribute earnings from the
         company, including your subsidiaries, to the parent company and U.S.
investors.
Item 1A. Risk Factors, page 14

5.       Revise your risk factors to acknowledge that if PRC regulations change
or are interpreted
         differently in the future, the securities you have registered may
decline in value or become
         worthless if the changes, or interpretations result in your inability
to assert contractual
         control over the assets of your PRC subsidiaries.
6.       We note your disclosure about the Holding Foreign Companies
Accountable Act on page
         15. Please enhance your disclosure to also disclose whether you have
been or expect to be
         identified by the Commission under the HFCAA and what impact this may
have on your
         ability to continue to offer your securities.
 Xiangyu Pei
CBAK Energy Technology, Inc.
October 27, 2022
Page 3
7.       We note your risk factor on page 19 that most of your officers and
directors are nationals
         or residents of China. As such, please revise to include a separate
Enforceability section
         to disclose the difficulty of bringing actions and enforcing
judgements against these
         individuals. Refer to Item 101(g) of Regulation S-K.
       In closing, 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.

       You may contact Jeffrey Gordon at 202-551-3866 or Jean Yu at
202-551-3305 with any
questions.



FirstName LastNameXiangyu Pei                                 Sincerely,
Comapany NameCBAK Energy Technology, Inc.
                                                              Division of
Corporation Finance
October 27, 2022 Page 3                                       Office of
Manufacturing
FirstName LastName