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                            June 26, 2023

       Nan Wang
       Chief Financial Officer
       SINOVAC BIOTECH LTD
       No. 39 Shangdi Xi Road
       Haidian District, Beijing 100085

                                                        Re: SINOVAC BIOTECH LTD
                                                            Form 20-F
                                                            Filed May 1, 2023
                                                            File No. 001-32371

       Dear Nan Wang:

              We have reviewed your filing 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.

       Annual Report on Form 20-F

       Introduction, page 1

   1.                                                   We note your carve-out
of Hong Kong and Macau in your definition of    China    and the
                                                           PRC.    Please
clarify that the legal and operational risks associated with operating in
                                                        China also apply to
operations in Hong Kong and Macau. Revise to clarify which of your
                                                        entities are domiciled
in or have operations in Hong Kong and/or Macau, and discuss the
                                                        applicable laws and
regulations in Hong Kong and/or Macau, as applicable, as well as the
                                                        related risks and
consequences.
   2.                                                   You state ""Sinovac,
   Sinovac Biotech,       Company,       we,       us,       our company,
and
                                                           our    refer to
Sinovac Biotech Ltd., its predecessor entities and its consolidated
                                                        subsidiaries" and that
"Sinovac Antigua    refers to Sinovac Biotech Ltd. Clearly disclose
                                                        how you will refer to
the holding company and subsidiaries when providing the disclosure
                                                        throughout the document
so that it is clear to investors which entity the disclosure is
 Nan Wang
SINOVAC BIOTECH LTD
June 26, 2023
Page 2
         referencing and which subsidiaries or entities are conducting the
business operations. For
         example, disclose, that your subsidiaries conduct operations in China.
Cash and Asset Flows Through Our Organization, page 2

3.       Provide a clear description of how cash is transferred through your
organization. Disclose
         your intentions to distribute earnings. We note you are paid dividends
by your
         subsidiaries, please quantify the dividends or distributions that a
subsidiary has made to
         the holding company and which entity made such transfer, and their tax
consequences.
         Quantify any cash flows that have occurred between the holding company
and its
         subsidiaries, and direction of transfer. Similarly quantify dividends
or distributions made
         to U.S. investors, the source, and their tax consequences. Your
disclosure should make
         clear if no transfers or distributions have been made to date.
Describe any restrictions and
         limitations on your ability to distribute earnings from the company,
including your
         subsidiaries, to the parent company and U.S. investors.
Part I
Item 3. Key Information, page 2

4.       At the onset of Part I, please disclose prominently that you are not a
Chinese operating
         company but an Antiguan holding company under the laws of Antigua and
Barbuda with
         operations conducted by your subsidiaries. In addition, we note your
company's corporate
         structure diagram on page 47, please provide it earlier in the Key
Information section.
5.       We note your disclosure regarding regulatory actions by China's
government and impact.
         Please also include how such statements or actions have or may impact
the company's
         ability to conduct its business, accept foreign investments, or list
on a U.S. or other
         foreign exchange.
6.     Disclose each permission or approval that you or your subsidiaries are
required to obtain
       from Chinese authorities to operate your business and to offer
securities to foreign
       investors. We note your discussion of the China Securities Regulatory
Commission
       (CSRC) and Cyberspace Administration of China (CAC) beginning on page
26, please
       state whether you or your subsidiaries are covered by permissions
requirements from the
       CSRC, CAC, or any other governmental agency that is required to approve
your
       operations, and state affirmatively whether you have received all
requisite permissions or
       approvals and whether any permissions or approvals have been denied.
Please also
       describe the consequences to you and your investors if you or your
subsidiaries: (i) do not
       receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such
FirstName LastNameNan Wang
       permissions or approvals are not required, or (iii) applicable laws,
regulations, or
Comapany    NameSINOVAC
       interpretations changeBIOTECH
                               and you areLTD
                                           required to obtain such permissions
or approvals in the
       future.
June 26, 2023 Page 2
FirstName LastName
 Nan Wang
FirstName
SINOVACLastNameNan   Wang
           BIOTECH LTD
Comapany
June       NameSINOVAC BIOTECH LTD
     26, 2023
June 26,
Page 3 2023 Page 3
FirstName LastName
Future changes in laws, regulations or enforcement policies..., page 26

7.       We note your risk factor disclosure regarding the China Securities
Regulatory
         Commission (CSRC) recent regulation relating to overseas offerings and
listings by PRC
         companies that went into effect March 31, 2023. Please revise to state
whether
         the Provisional Measures apply to the company and discuss potential
risks to investors if
         the company were to be found noncompliant.
Risks Related to Doing Business in China, page 26

8.       We note the disclosed risk factors arising from the legal system in
China and government
         involvement. Please also include that any actions by the Chinese
government to exert
         more oversight and control over offerings that are conducted overseas
and/or foreign
         investment in China-based issuers could significantly limit or
completely hinder your
         ability to offer or continue to offer securities to investors and
cause the value of your
         securities to significantly decline or be worthless.
Complying with evolving laws and regulations regarding cybersecurity..., page
27

9.       In light of recent events indicating greater oversight by the
Cyberspace Administration of
         China (CAC) over data security, particularly for companies seeking to
list on a foreign
         exchange, please revise your disclosure to explain how this oversight
impacts your
         business and your securities and to what extent you believe that you
are compliant with
         the regulations or policies that have been issued by the CAC to date.
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 53

10.      Please expand your discussions of trends between comparative periods
to more clearly
         identify the factors driving the changes experienced and to provide
quantification where
         possible for each factor cited. As part of your response, please
specifically address the
         following:
             You disclose on page 55 that the decrease was mainly due to the
decreased sales of
              COVID-19 vaccine. You also state that your gross profit declined
due to the decrease
              of the average selling price of COVID-19 vaccines. Revise to
separately quantify the
              revenue from the COVID-19 vaccine for each of your three market
types listed here,
              and quantify the extent to which the decrease in sales of
COVID-19 vaccine was due
              to lower price of the vaccine versus lower volume of doses sold.
             You disclose on page 54 that a portion of your Cost of sales as
"idle capacity"
              including $97.5 million in 2022. Revise to more clearly disclose
the reasons for the
              idle capacity in each of the periods presented.
             You disclose on page 55 that the increase in Selling, general, and
administrative
              expenses in 2022 was mainly due to the establishment of a
long-term employee
              incentive plan offset by lower selling expenses. Revise this
section to quantify each
              of these factors.
 Nan Wang
FirstName
SINOVACLastNameNan   Wang
           BIOTECH LTD
Comapany
June       NameSINOVAC BIOTECH LTD
     26, 2023
June 26,
Page 4 2023 Page 4
FirstName LastName
                You disclose on page 55 that your Research and development
expenses "primarily
              represented expenditures on the advancement of pipeline vaccines"
without further
              explanation for the changes between periods. Revise to more
clearly identify the
              reasons for the 185% increase in these expenses from 2021 to
2022. Consider
              providing a breakdown of such expenses by product candidate, and
for any expenses
              that are not allocated to a specific product candidate, consider
providing a breakdown
              by type of expense.
                Revise to discuss the changes reflected in your Other income
(expense), net line item,
              given the change from negative $90 million in 2021 to positive
$302 million in
              2022.
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent, page 94

11.      We note your statement that you reviewed public filings made by your
shareholders in
         connection with your required submission under paragraph (a). Please
supplementally
         describe any additional materials that were reviewed and tell us
whether you relied upon
         any legal opinions or third party certifications such as affidavits as
the basis for your
         submission. In your response, please provide a similarly detailed
discussion of the
         materials reviewed and legal opinions or third party certifications
relied upon in
         connection with the required disclosures under paragraphs (b)(2) and
(3).
12.      In order to clarify the scope of your review, please supplementally
describe the steps you
         have taken to confirm that none of the members of your board or the
boards of your
         consolidated foreign operating entities are officials of the Chinese
Communist Party. For
         instance, please tell us how the board members    current or prior
memberships on, or
         affiliations with, committees of the Chinese Communist Party factored
into your
         determination. In addition, please tell us whether you have relied
upon third party
         certifications such as affidavits as the basis for your disclosure.
13.      We note that your disclosures pursuant to Items 16I(b)(2) that no
Antigua or PRC
         governmental entities owns any shares of Sinovac Antigua or its
subsidiaries. We also
         note that your list of subsidiaries in Exhibit 8.1 appears to indicate
that you have
         subsidiaries in Hong Kong and countries outside China. Please note
that Item 16I(b)
         requires that you provide disclosures for yourself and your
consolidated foreign operating
         entities, including variable interest entities or similar structures.
             With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
              consolidated foreign operating entities are organized or
incorporated and provide the
              percentage of your shares or the shares of your consolidated
operating entities owned
              by governmental entities in each foreign jurisdiction in which
you have consolidated
              operating entities in your supplemental response.

        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.
 Nan Wang
SINOVAC BIOTECH LTD
June 26, 2023
Page 5

        You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Contact
Austin Pattan at (202) 551-6756 or Andrew Mew at (202) 551-3377 if you have any
questions
about comments related to your status as a Commission-Identified Issuer during
your most
recently completed fiscal year. Please contact Doris Stacey Gama at
202-551-3188 or Jason
Drory at 202-551-8342 with any other questions.



                                                        Sincerely,
FirstName LastNameNan Wang
                                                        Division of Corporation
Finance
Comapany NameSINOVAC BIOTECH LTD
                                                        Office of Life Sciences
June 26, 2023 Page 5
cc:       Benjamin Su, Esq.
FirstName LastName