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                              September 1, 2020

       Gang Lai
       Chief Executive Officer
       Universe Pharmaceuticals Inc.
       265 Jingjiu Avenue
       Jingii Jishu Kaifa District
       Jiangxi, China

                                                        Re: Universe
Pharmaceuticals Inc.
                                                            Registration
Statement on Form F-1
                                                            Filed August 17,
2020
                                                            File No. 333-248067

       Dear Mr. Lai:

              We have reviewed your registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1 filed August 17, 2020

       Exhibits

   1.                                                   Please have counsel to
revise the Exhibit 5.1 opinion to opine that the warrants will be
                                                        binding obligations of
the company, and to opine on the ordinary shares underlying the
                                                        warrants that are also
being registered, in accordance with Section II.B.1.f of Staff Legal
                                                        Bulletin No. 19.
   2.                                                   The Exhibit 5.1 opinion
should not assume conclusions of law that are necessary for the
                                                        ultimate opinion.
Please filed a revised Exhibit 5.1 opinion that does not include the
                                                        assumptions set forth
in paragraphs (9), (10), (11), (12), (14), (15), (16) and (18) of
                                                        Schedule 2. For
guidance, please refer to Section II.B.3.a of Staff Legal Bulletin No. 19.
 Gang Lai
Universe Pharmaceuticals Inc.
September 1, 2020
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Michael Fay at 202-551-3812 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Alan Campbell at 202-551-4224 or Celeste Murphy at 202-551-3257 with any other
questions.



                                                           Sincerely,
FirstName LastNameGang Lai
                                                           Division of
Corporation Finance
Comapany NameUniverse Pharmaceuticals Inc.
                                                           Office of Life
Sciences
September 1, 2020 Page 2
cc:       Ying Li, Esq.
FirstName LastName