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                            July 26, 2022

       Long Chen
       Chief Executive Officer
       ZKH Group Limited
       7/F, Tower 4, Libao Plaza, No. 36 Shenbin Road
       Minhang District, Shanghai 201106
       People   s Republic of China

                                                        Re: ZKH Group Limited
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted July 12,
2022
                                                            CIK No. 0001862044

       Dear Mr. Chen:

             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 with
information so 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 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 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 No. 2 to Draft Registration Statement on Form F-1 Submitted on
July 12, 2022

       Cover Page

   1.                                                   We reissue our prior
comment 3 in part. Please quantify the proceeds from the issuance of
                                                        Series F Convertible
Notes that was transferred between you and your subsidiaries. Make
                                                        conforming changes in
your prospectus summary.
 Long Chen
FirstName
ZKH GroupLastNameLong Chen
            Limited
Comapany
July       NameZKH Group Limited
     26, 2022
July 26,
Page  2 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
91

2.       We have reviewed your response to comment 7 noting GMV represents
sales on a gross
         basis under both the sales model and marketplace model even though
sales are recognized
         on a net basis under the marketplace model under U.S. GAAP. Please
tell us how you
         determined that the disclosure of this measure does not result in a
tailored recognition and
         measurement method. Refer to Question 100.04 of the staff's Compliance
and Disclosure
         Interpretations on Non-GAAP Financial Measures.
3.       We note your response to our prior comment 9. Please disclose your
response in your
         filing.
General

4.       We note your disclosure throughout your filing that your business
strategy includes
         expansion into overseas markets. We also note the information on slide
19 of your "testing
         the waters" materials regarding the "untapped and massive" market in
certain overseas
         territories. Please include such disclosure in your filing, or tell us
why you are not
         required to do so.
       You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Donald Field at 202-551-3680 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
cc:      Brian V. Breheny, Esq.