April 20, 2020

Jueqin Wang
Chief Executive Officer
Huadi International Group Co., Ltd.
No. 1688 Tianzhong Street, Longwan District
Wenzhou, Zhejiang Province
People's Republic of China 325025

       Re: Huadi International Group Co., Ltd.
           Amendment 2 to Draft Registration Statement on Form F-1
           Submitted April 10, 2020
           CIK 0001791725

Dear Mr. Wang:

        We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments we may ask you to provide us information so
that we may
better understand your disclosure.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe that our comments apply to your facts and
circumstances or do
not believe that an amendment is appropriate, please tell us why in your
response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment 2 to Draft Registration Statement on Form F-1 submitted April 10,
2020

Coronavirus (COVID-19) Update, page 8

1.     We note your added disclosure on pages 8, 16, and 34 regarding the
COVID-19 virus. In
       addition to disclosing what may, might, or could happen as a result of
the pandemic,
       please also revise to discuss clearly what has happened and the effect
on your operations
       and financial condition. For example, clarify your disclosure on page 34
that you "might"
       see a slowdown in revenue in your first and second quarters to specify
whether, in fact,
       you have experienced such a slowdown and, if known, the magnitude. Also
clarify your
       disclosures on pages 8 and 16 to clarify whether you have experienced a
slowdown or
       suspension in production, for how long your facilities were closed, and
whether your
 Jueqin Wang
Huadi International Group Co., Ltd.
April 20, 2020
Page 2
      collections and customers have been affected.
Management, page 59

2.    We note your response to prior comment 2. Please reconcile your deletions
from pages 59
      and II-5 that Huisen Wang is not a director with the continued disclosure
on page 60 that
      he is a director. Please also reconcile Exhibit 10.5, which states Mr. Li
will be chair of the
      nominating committee, with your disclosures on pages 59 and 61, which
state that Mr. Li
      will be chair of the compensation committee.
        You may contact SiSi Cheng, Staff Accountant, at (202) 551-5004 or W.
John Cash,
Accounting Branch Chief, at (202) 551-3768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
(202) 551-3728 or Geoffrey D. Kruczek, Senior Counsel, at (202)551-3641 with
any other
questions.



                                                             Sincerely,
FirstName LastNameJueqin Wang
                                                             Division of
Corporation Finance
Comapany NameHuadi International Group Co., Ltd.
                                                             Office of
Manufacturing
April 20, 2020 Page 2
cc:       William S. Rosenstadt, Esq.
FirstName LastName