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                             November 19, 2021

       Ivan Hsia
       Chief Financial Officer
       ASIA PACIFIC WIRE & CABLE CORP LTD
       15/Fl. B, No. 77, Sec. 2
       Dunhua South Road
       Taipei, 106, Taiwan
       Republic of China

                                                        Re: ASIA PACIFIC WIRE &
CABLE CORP LTD
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed September 2,
2021
                                                            File No. 333-257970

       Dear Mr. Hsia:

             We have reviewed your amended registration statement 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.

       Amendment No. 1 to Form F-1 filed September 2, 2021

       Prospectus Cover Page, page i

   1.                                                   Provide a description
of how cash is transferred through your organization and disclosure
                                                        regarding your
intentions to distribute earnings or settle amounts owed under your
                                                        agreements. State
whether any transfers, dividends, or distributions have been made to
                                                        date.
       Prospectus Summary, page 8

   2.                                                   Please disclose whether
you are required to obtain any approvals to offer securities to
                                                        foreign investors,
whether you have received such approvals and the consequences to you
 Ivan Hsia
ASIA PACIFIC WIRE & CABLE CORP LTD
November 19, 2021
Page 2
      and your investors if you do not receive or maintain the approvals,
inadvertently conclude
      that such approvals are not required, or applicable laws, regulations, or
interpretations
      change and you are required to obtain approval in the future.
Risk Factors, page 16

3.    Please expand your risk factor disclosure to discuss that the United
States Senate passed
      the Accelerating Holding Foreign Companies Accountable Act, which, if
enacted, would
      decrease the number of non-inspection years from three years to two, thus
reducing the
      time period before your securities may be prohibited from trading or
delisted.
       Please contact Geoff Kruczek at (202) 551-3641 or Anne Parker, Office
Chief, at (202)
551-3611 with any questions.



                                                           Sincerely,
FirstName LastNameIvan Hsia
                                            Division of Corporation Finance
Comapany NameASIA PACIFIC WIRE & CABLE CORP LTD
                                            Office of Manufacturing
November 19, 2021 Page 2
cc:       Benjamin Fackler
FirstName LastName