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                             July 12, 2023

       Ban Siong Ang
       Chief Executive Officer
       Heyu Biological Technology Corp
       Room 1901, Baotuo Building, 617 Sishui Street
       Huli District, Xiamen City,
       Fujian Province, China 361009

                                                        Re: Heyu Biological
Technology Corp
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed March 23,
2023
                                                            File No. 000-26731

       Dear Ban Siong Ang:

              We have reviewed your June 22, 2023 response to our comment
letter 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.

       Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 17

   1.                                                   Please provide us with
your proposed revised disclosure to be included in future filings to
                                                        address the following:
                                                            Revise your
Business section and MD&A to more clearly identify your products and
                                                            revenue streams.
                                                            Provide a breakdown
of your revenues and cost of goods sold by product type. To the
                                                            extent your tabular
breakdown of your Cost of revenues (i.e. Disinfectant sprays,
                                                            Healthcare
instruments and Other) on page 18 represents the way you view your
                                                            product types,
revise your future filings to break out revenues earned for the periods
                                                            presented into the
same categories. Provide us with such a breakdown in your
                                                            response.
 Ban Siong Ang
Heyu Biological Technology Corp
July 12, 2023
Page 2
                Expand your disclosure on page 17 to describe the reasons for
the increase in
              revenue. For example, discuss the extent to which changes in
revenue were driven by
              prices vs volumes and the degree to which specific products or
groups of products
              impacted sales levels.
                Revise the disclosure on page 17 to clarify whether all of the
revenue is related party.
              Your disclosure on page F-15 states that all of your products are
sold to your Chief
              Executive Officer and director of the Company, Mr. Ban Siong Ang.
However, the
              disclosure on page 17 states that you sign a purchase and sale
agreement with a
              customer, the customer then makes payment to Mr. Ban Siong Ang
which is
              transferred to the Company, and then the goods are delivered to
the customer. Please
              clarify if the products are sold to third party customers or only
to Mr. Ban Siong Ang.
              Revise to clearly explain the business purpose of such an
arrangement.
                The revenue recognition section you added on page 18 only
addresses the payment
              deposit. Please provide us revised disclosure to be included in
future filings to also
              include the revenue recognition policy for the orders disclosed
on page 17.
2.       The disclosure you added on page 18 states that you have classified
the deposit received
         from the customer as "unearned revenue". However, it appears that it
is classified as
         "Advances from customers" on the Balance Sheet. Please clarify. In
addition, please
         explain why the deposit is classified as a current liability since you
disclose that you are
         currently unable to determine when the revenue can be recognized.
3.       We note that you added a Cost of Revenue section on page 18. Please
confirm that in
         future filings you will add a line item for Cost of Revenue to the
table on page 17 so that it
         is clear to an investor that the balance is also included in the
computation of Loss from
         Operations.
       You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
202-551-3494
with any questions.



FirstName LastNameBan Siong Ang                                 Sincerely,
Comapany NameHeyu Biological Technology Corp
                                                                Division of
Corporation Finance
July 12, 2023 Page 2                                            Office of Life
Sciences
FirstName LastName