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                              August 4, 2023

       Zhu Runzhou
       Chief Executive Officer
       Aluminum Corporation of China Limited
       No. 62 North Xizhimen Street, Haidian District, Beijing
       People   s Republic of China ( 100082 )

                                                        Re: Aluminum
Corporation of China Limited
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-15264

       Dear Zhu Runzhou:

              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 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.

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

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

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 139

   1.                                                   We note your
disclosures on pages iii, iv, vi, and 139. Please confirm, if true, that you
are
                                                        controlled by the
State-owned Assets Supervision and Administration Commission of the
                                                        State Council of China
by virtue of the SASAC   s total ownership of your controlling
                                                        shareholder. Please
also briefly explain the State Council of China and the SASAC   s role
                                                        as governmental
entities.
 Zhu Runzhou
FirstName
Aluminum LastNameZhu
           Corporation ofRunzhou
                         China Limited
Comapany
August     NameAluminum Corporation of China Limited
       4, 2023
August
Page 2 4, 2023 Page 2
FirstName LastName
2.       We note that your principal subsidiaries provided in Note 1 to your
consolidated financial
         statements indicates that you have a subsidiary in Hong Kong. Please
note that Item
         16I(b) requires that you provide disclosures for yourself and all of
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.
                With respect to (b)(3), (b)(4), and (b)(5), please provide the
required information for
              you and all of your consolidated foreign operating entities in
your supplemental
              response.
3.       Please supplementally describe the 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 disclosure under paragraphs (b)(2) and (3).
4.       We note your disclosure at page 139 that eight of your directors are
 members of the
         Chinese Communist Party.    Please further identify each    official
 of the Chinese
         Communist Party as required by Item 16I(b)(4) of the Form 20-F.
5.       In order to clarify the scope of your review, please supplementally
describe the steps you
         have taken to identify whether 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.
6.       With respect to your disclosure pursuant to Item 16I(b)(5), please
confirm that your
         Articles of Association contain one or more charters of the Chinese
Communist Party, or
         the text of any such charters, and tell us the text of such charters.
We also note that you
         have included language that such disclosure is    to our best
knowledge.    Please
         supplementally confirm without qualification, if true, that your
articles and the articles of
         your consolidated foreign operating entities do not contain wording
from any charter of
         the Chinese Communist Party other than those outlined in your
response.
 Zhu Runzhou
FirstName
Aluminum LastNameZhu
           Corporation ofRunzhou
                         China Limited
Comapany
August     NameAluminum Corporation of China Limited
       4, 2023
August
Page 3 4, 2023 Page 3
FirstName LastName
        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 Kyle Wiley at (202) 344-5791 or Christopher Dunham at
(202) 551-3783
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Disclosure Review
Program
cc:      Chin-Yang Lin