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                            December 5, 2023

       Wanjun Yao
       Chief Executive Officer
       Tungray Technologies Inc.
       #02-01, 31 Mandai Estate,
       Innovation Place Tower 4,
       Singapore 729933

                                                        Re: Tungray
Technologies Inc.
                                                            Amendment No. 7 to
Registration Statement on Form F-1
                                                            Filed November 29,
2023
                                                            File No. 333-270434

       Dear Wanjun Yao:

                                                        We have reviewed your
amended registration statement and have the following comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our November 16,
2023 letter.

       Amendment No. 7 to Registration Statement on Form F-1

       Financial Statements
       Note 2. Summary of significant accounting policies
       Prepayments, page F-10

   1.                                                   We note your response
to the prior comment and your revised disclosures on pages F-10
                                                        and F-42. Please expand
your disclosures to address the following points.
                                                            Please clarify why
agreements for inventory costs paid to suppliers and service fees
                                                            paid to providers
must be prepaid and explain how the amounts are determined
                                                            according to the
respective agreements.
                                                            With regard to your
policy disclosure stating that you review the prepaid
                                                            amounts
periodically and use an "aging method" and "specific losses on individual
                                                            exposures...to
estimate the allowance for uncollectible or unrealized balances,
                                                            describe the manner
by which you assess this ability and determine whether a general
 Wanjun Yao
Tungray Technologies Inc.
December 5, 2023
Page 2
           allowance or a specific impairment is appropriate and necessary.
Also describe the
           provisions of the agreements, if any, under which a supplier or
provider would be
           required to refund the amounts advanced.
             Identify any aspects of your periodic reviews of the amounts
advanced which
           evaluate recoverability based on the market values (quantity or
price guarantees) of
           the contracted volumes of inventory that will be received in
satisfaction of these
           amounts.
             Please identify the specific authoritative accounting literature
that you have relied
           upon in accounting for these agreements, considering any provisions
for quantity and
           price guarantees, and recovery of cash advances.

        Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-3361
if you have questions regarding comments on the financial statements and
related matters. Please
contact Kyle Wiley at 202-344-5791 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                           Sincerely,
FirstName LastNameWanjun Yao
                                                           Division of
Corporation Finance
Comapany NameTungray Technologies Inc.
                                                           Office of Technology
December 5, 2023 Page 2
cc:       Anna Jinhua Wang
FirstName LastName