United States securities and exchange commission logo





                          May 18, 2021

       Dandan Liu
       Chief Executive Officer
       TDH Holdings, Inc.
       c/o Qingdao Tiandihui Foodstuffs Co. Ltd.,
       2521 Tiejueshan Road, Huangdao District
       Qingdao, Shandong Province
       People   s Republic of China

                                                        Re: TDH Holdings, Inc.
                                                            Registration
Statement on Form F-3
                                                            Filed May 12, 2021
                                                            File No. 333-256042

       Dear Ms. Liu:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Charles
Eastman at 202-551-3794 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing