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                              July 20, 2023

       David Leung
       Chief Executive Officer
       Euro Tech Holdings Company Limited
       Unit D, 18/F, Gee Chang Hong Centre
       65 Wong Chuk Hang Road
       Hong Kong

                                                        Re: Euro Tech Holdings
Company Limited
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 000-22113

       Dear David Leung:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F and have the following comment. In our
comment, we may
       ask you to provide us with information so we may better understand your
disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       General

   1.                                                   We note that during
your fiscal year 2022 you were identified by the Commission
                                                        pursuant to Section
104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C.
                                                        7214(i)(2)(A)) as
having retained, for the preparation of the audit report on your financial
                                                        statements included in
the Form 20-F, a registered public accounting firm that has a
                                                        branch or office that
is located in a foreign jurisdiction and that the Public Company
                                                        Accounting Oversight
Board had determined it is unable to inspect or investigate
                                                        completely because of a
position taken by an authority in the foreign jurisdiction. Please
                                                        provide the
documentation required by Item 16I(a) of Form 20-F or tell us why you are
                                                        not required to do so.
Additionally, please amend your Form 20-F to provide the
                                                        disclosures required
under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the
                                                        Holding Foreign
Companies Accountable Act and the Consolidated Appropriations Act,
                                                        2023, available on our
website at https://www.sec.gov/corpfin/announcement/statement-
                                                        hfcaa-040623.
 David Leung
Euro Tech Holdings Company Limited
July 20, 2023
Page 2

        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 Tyler Howes at 202-551-3370 or Christopher Dunham at
202-551-3783
with any questions.



FirstName LastNameDavid Leung                             Sincerely,
Comapany NameEuro Tech Holdings Company Limited           Division of
Corporation Finance
July 20, 2023 Page 2
cc:       Richard Friedman, Esq.
FirstName LastName