December 20, 2018

Zeshu Dai
Chief Executive Officer
China Xiangtai Food Co., Ltd.
c/o Chongqing Penglin Food Co., Ltd.
Xinganxian Plaza
Building B, Suite 21-1
Lianglukou, Yuzhong District 400800
Chongqing, People's Republic of China

       Re: China Xiangtai Food Co., Ltd.
           Post-Effective Amendment No. 1 to
           Registration Statement on Form F-1
           Filed November 20, 2018
           File No. 333-226990

Dear Ms. Dai:

       We have reviewed your post-effective amendment 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.

Post-Effective Amendment of Form F-1 filed November 20, 2018

General

1.     We note your response to our prior comment 1 that you did not engage in
any offer or sale
       of your securities between October 1, 2018 and the date of your December
12, 2018
       response letter. However, we also note that you filed a free writing
prospectus on October
       30, 2018. Section 2(a)(3) of the Securities Act defines the term "offer"
to include "every
       attempt or offer to dispose of, or solicitation of an offer to buy, a
security or interest in a
       security, for value." Rule 405 of the Securities Act defines a free
writing prospectus as
 Zeshu Dai
China Xiangtai Food Co., Ltd.
December 20, 2018
Page 2
         "any written communication as defined in this section that constitutes
an offer to sell or
         a solicitation of an offer to buy the securities related to a
registered offering that is used
         after the registration statement in respect of the offering is filed."
In light of this please
         explain to us why you believe that you did not engage in any offer of
your securities
         between October 1, 2018 and the date of your December 12, 2018
response letter.
         Additionally we note that the free writing prospectus was filed on
Edgar and thus publicly
         available and widely disseminated. In light of that provide us your
analysis of your
         potential Section 5 liability and tell us what disclosure may be
necessary related to
         contingent liability and rescission.
        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.

       Please contact John Stickel at 202-551-3324 or John Dana Brown at
202-551-3859 with
any questions.



FirstName LastNameZeshu Dai                                     Sincerely,
Comapany NameChina Xiangtai Food Co., Ltd.
                                                                Division of
Corporation Finance
December 20, 2018 Page 2                                        Office of
Transportation and Leisure
FirstName LastName