June 29, 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.
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted June 14, 2018
           CIK No. 0001735556

Dear Ms. Dai:

      We have reviewed your amended draft registration statement and have the
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

Amendment No. 1 to Form F-1 DRS submitted June 14, 2018

Cover Page

1.     We note your response to our prior comment 3. Please revise your
disclosure to clarify
       that you will return funds to investors within one business day to be
consistent with your
       disclosure on page 109.
 Zeshu Dai
China Xiangtai Food Co., Ltd.
June 29, 2018
Page 2
Management's Discussion and Analysis
Key Factors that Affect Operating Results, page 45

2.       We note your response to our prior comment 12 and reissue in part. In
addition to the two
         grocery stores you are planning to acquire, you disclose on page 46
that after the initial
         public offering you are considering opening or acquiring your own
specialty, or grocery
         store to sell your meat products. Please discuss the material steps
and costs involved with
         such endeavors.
Corporate History and Structure, page 67

3.       We note your response to our prior comment 19 and reissue. Please
briefly disclose in
         this section the reason for conducting your operations through
contractual arrangements
         rather than direct ownership of CQ Penglin.
Related Party Transactions, page 89

4.       Please include the disclosure required by Item 7.B of Form 20-F
regarding the acquisition
         of two grocery stores from your CEO and her spouse in this section.
Principal Shareholders, page 90

5.       We note the revised disclosure on page 83 that you now have five
additional directors.
         Please update your beneficial ownership table on page 91 accordingly.
       You may contact Amy Geddes at 202-551-3304 or Andrew Mew at 202-551-3377
if you
have questions regarding comments on the financial statements and related
matters. Please
contact John Stickel at 202-551-3324 or Justin Dobbie, Legal Branch Chief, at
with any other questions.

FirstName LastNameZeshu Dai
Comapany NameChina Xiangtai Food Co., Ltd.
                                                              Division of
Corporation Finance
June 29, 2018 Page 2                                          Office of
Transportation and Leisure
FirstName LastName