February 14, 2020

Martyn Wade
Chief Executive Officer
Grindrod Shipping Holdings Ltd.
#03-01 Southpoint
200 Cantonment Road
Singapore 089763

       Re: Grindrod Shipping Holdings Ltd.
           Form 20-F for the Fiscal Year ended December 31, 2018
           Filed April 16, 2019
           File No. 001-38440

Dear Mr. Wade:

       We have reviewed your January 23, 2020 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. Unless we note otherwise, our references to prior comments are to
comments in
our December 23, 2019 letter.

Form 20-F for the Fiscal Year ended December 31, 2018

Note 2- Signifcant Accounting Policies, page F-2

1.    We note your response to prior comment four and the accounting policy
disclosure that
      you propose, which includes indicators that correlate with your status as
pool
      manager/principal for contracts between customers and the IVS Handysize
Pool and the
      IVS Supramax Pool. Please also disclose how the pools are structured from
a legal
      standpoint, including the nature and extent of your ownership and control
over the pools
      and the vessels; and how you are accounting for contracts between the
pools and vessel
      owners. Tell us how you have assessed IFRS 16, paragraphs 9 and B9-B33,
for
      agreements under which you secure rights to control vessels in the pools;
relative to your
      views under IFRS 15, including paragraph 33, regarding the ability to
prevent other
 Martyn Wade
Grindrod Shipping Holdings Ltd.
February 14, 2020
Page 2
         entities from directing the use of, and obtaining the benefits from an
asset; and paragraph
         B35A(b), on the ability to direct vessel owners to provide the service
on your behalf.

         The disclosures you have referenced on pages 33 and 34 indicate that
while you as the
         pool manager are responsible for administrative and commercial
management of the pool,
         the vessel owners are responsible for manning and technical management
of their vessels.
         Please clarify whether the roles ascribed to the pool manager among
the indicators you
         have listed are exclusively yours as the pool manager, or are shared
in any degree with the
         vessel owners. Please describe any circumstances under which specific
vessels or their
         owners are identified in contracts with customers for vessels in the
pools, and any
         instances of vessel owners sharing or having any involvement in the
commercial
         management of vessels that they have placed in the pools, such as
discretion in accepting
         a contract or establishing the price that end charterers will pay.

         Please describe the general terms and duration of contracts with
participating vessel
         owners, including any provisions for renewal, suspending
participation, or for removing
         vessels from the pool prior to completing the stated term of the pool
arrangement. Please
         submit copies of the agreements governing participation in your IVS
Handysize Pool and
         the customer contracts of that pool that were the most significant
during 2018; identify
         any provisions among these contracts that are not representational of
or consistent with the
         provisions of other contracts with other participants and customers of
this pool.
       You may contact John Cannarella, Staff Accountant at (202) 551-3337 or
Jenifer
Gallagher, Staff Accountant, at (202) 551-3706 with any questions.



FirstName LastNameMartyn Wade                                  Sincerely,
Comapany NameGrindrod Shipping Holdings Ltd.
                                                               Division of
Corporation Finance
February 14, 2020 Page 2                                       Office of Energy
& Transportation
FirstName LastName