Mail Stop 3561

                                                                September 7,
2018


    Adeline Gu
    Chief Financial Officer
    China Recycling Energy Corporation
    4/F, Tower C
    Rong Cheng Yun Gu Building
    Keji 3rd Road, Yanta District
    Xi'an City, Shaanxi Province
    China 710075

            Re:    China Recycling Energy Corporation
                   Form 10-K for the Fiscal Year Ended December 31, 2017
                   Filed April 13, 2018
                   File No. 1-34625

    Dear Ms. Gu:

           We have limited our review of your filing to the financial
statements and related
    disclosures 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.

    Item 8. Financial Statements and Supplementary Data

    1. Organization and Description of Business

    Erdos TCH   Joint Venture, page F-6

        1. Reference is made to the supplemental agreement effective May 1,
2016 whereby Erdos
           TCH canceled monthly minimum lease payments from Erdos and charges
Erdos based on
           actual electricity sold. Referencing authoritative literature that
supports your accounting
           treatment, please explain to us how you evaluated and accounted for
the lease
           modification. Refer to ASC 840-30-35-30 and 840-30-40-6. In doing
so, please tell us
 Adeline Gu
China Recycling Energy Corporation
September 7, 2018
Page 2

       whether you consider the payments based on actual electricity sold under
the
       supplemental agreement minimum lease payments as defined in ASC
840-10-25-4.

2. Summary of Significant Accounting Policies

Basis of Presentation, page F-13

    2. You disclose that certain information and footnote disclosures normally
present in annual
       financial statements prepared in accordance with accounting principles
generally
       accepted in the United States of America were omitted. Please tell the
information and
       footnote disclosures that have been omitted.

16. Income Tax, page F-25

    3. In future filings, please disclose the total valuation allowance
recognized for deferred tax
       assets. Refer to ASC 740-10-50-2c. Please also disclose the amounts and
expiration
       dates of the PRC NOLs. Refer to ASC 740-10-50-3a.

Item 9A. Controls and Procedures

Internal Controls Over Financial Reporting, page 50

    4. Please amend to disclose a statement as to whether or not internal
control over financial
       reporting was effective as of December 31, 2017. In this regard, your
current disclosure
       states that your assessment was as of December 31, 2015. Refer to Item
308(a)(3) of
       Regulation S-K.

        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.

      You may contact Adam Phippen, Staff Accountant, at (202) 551-3336 or me
at (202)
551-3344 with any questions.


                                                             Sincerely,

                                                             /s/ William H.
Thompson

                                                             William H.
Thompson
                                                             Accounting Branch
Chief
                                                             Office of Consumer
Products