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                             August 5, 2020

       Conn Flanigan
       General Counsel
       China Foods Holdings Ltd.
       Suite 3102, Everbright Center,
       108 Gloucester Road
       Wanchai, Hong Kong

                                                        Re: China Foods
Holdings Ltd.
                                                            Form 8-K Filed July
9, 2020
                                                            File No. 001-32522

       Dear Mr. Flanigan:

              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.

       Form 8-K filed July 9, 2020

       Description of Business of Elite Creation Group Limited, page 3

   1.                                                   Please revise your
disclosure in this section to provide more detailed information
                                                        regarding the formation
and operating history of Elite Creation Group Limited prior to its
                                                        acquisition by the
company. Refer to Item 101 of Regulation S-K.
       Key Customers, page 4

   2.                                                   We note your disclosure
on page 4 regarding the company's key customers. Please advise
                                                        us whether there are
any agreements in place with each customer and if so, provide your
                                                        analysis regarding the
need to file such agreements as material contracts pursuant to Item
                                                        601(b)(10)(ii)(B) of
Regulation S-K.
 Conn Flanigan
FirstName  LastNameConn
China Foods  Holdings Ltd. Flanigan
Comapany
August     NameChina Foods Holdings Ltd.
       5, 2020
August
Page 2 5, 2020 Page 2
FirstName LastName
Employees, page 14

3.       We note your statement on page 14 that you generally enter into
standard employment
         contracts with your officers and managers, which agreements prohibit
such individuals
         from engaging in any activities that compete with the company's
business during the
         period of employment. However, on page 41 you state that your
executive officers are not
         party to employment agreements with the company. Please reconcile
these statements. In
         addition, in the event Mr. Kong is not currently prohibited from
competing with the
         business of the company, please include a risk factor to this effect.
Risk Factors, page 15

4.       Please add a risk factor to describe the potential impact on the
operation of the company
         of Mr. Kong holding the role of both CEO and CFO, with no other named
executive
         officers in place.
Risks Related to Doing Business in China, page 25

5.       To the extent applicable, please include disclosure related to any new
restrictions on the
         ability to bring actions under Article 177 of the new amendments to
the Chinese securities
         laws that took effect on March 1, 2020. Your expanded disclosure
should specifically
         address the limitations and obstacles to enforcement actions by the
Department of Justice,
         the SEC and other authorities on obtaining information for
investigation and litigation.
         Please also add a risk factor that addresses the limitations on the
ability of U.S. regulators
         to conduct investigations and inspections within China.
The PRC legal system embodies uncertainties which could limit the legal
protections available to
us and you..., page 26

6.       We note your disclosure that your PRC operating subsidiary is
GuangZhou Xiao Xiang
         Health Industry Company Limited. Please ensure the name of your
subsidiaries in
         consistent throughout the prospectus and Exhibit 21. In this regard,
we note that you refer
         to "Guangzhou Xiaoziang Health Industry Ltd" in some instances and in
others
         "Guangzhou Xiao Xiang Health Industry Company Limited." Please revise,
where
         appropriate.
Security Ownership of Certain Beneficial Owners and Management , page 37

7.       We note the beneficial ownership table on page 37, which discloses
that Xiao Jun Kong is
         the beneficial owner of 18,951,000 of the company's outstanding
shares, 5,001,000 of
         which are held through HY (HK) Financial Investments Co., Ltd. You
also state that such
         ownership amounts to 93.57% of the company's outstanding shares.
However, on page 2
         you state that HY holds 5,000,000 shares which represent approximately
95.2% of the
         issued and outstanding shares of common stock. Please reconcile these
statements.

         In addition, we note your statement on page 20 that Mr. Kong
beneficially owns 93.57%
 Conn Flanigan
China Foods Holdings Ltd.
August 5, 2020
Page 3
         of the outstanding shares "together with a group of investors". Please
disclose the current
         ownership structure of HY, as we note that previous public filings
with the SEC stated
         that Mr. Kong was the sole shareholder of the entity.
Certain Relationships and Related Transactions, page 43

8.       We note your reference to $120,000 in the first paragraph of this
section. Please see the
         threshold mentioned in Regulation S-K Item 404(d)(1) applicable to
smaller reporting
         companies, and ensure that you have provided all disclosure required
by Item 404(d).
Description of Securities, page 44

9.     We note that your forum selection provision in your certificate of
incorporation identifies
       the Court of Chancery as the exclusive forum for certain litigation,
including any
       "derivative action." Please revise your filing to clearly describe this
provision and to
       describe any risks or other impacts on investors. Risks may include, but
are not limited to,
       increased costs to bring a claim and that these provisions can
discourage claims or limit
       investors    ability to bring a claim in a judicial forum that they find
favorable. Also
       disclose whether this provision applies to actions arising under the
Securities Act or
       Exchange Act. In that regard, we note that Section 27 of the Exchange
Act creates
       exclusive federal jurisdiction over all suits brought to enforce any
duty or liability created
       by the Exchange Act or the rules and regulations thereunder, and Section
22 of the
       Securities Act creates concurrent jurisdiction for federal and state
courts over all suits
       brought to enforce any duty or liability created by the Securities Act
or the rules and
       regulations thereunder. If the provision applies to Securities Act
claims, please also revise
       your filing to state that there is uncertainty as to whether a court
would enforce such
       provision and that investors cannot waive compliance with the federal
securities laws and
       the rules and regulations thereunder. If this provision does not apply
to actions arising
       under the Securities Act or Exchange Act, please also ensure that the
exclusive forum
FirstName LastNameConn Flanigan
       provision in the governing document states this clearly, or tell us how
you will inform
Comapany    NameChina
       investors in futureFoods   Holdings
                            filings that the Ltd.
                                             provision does not apply to any
actions arising under the
       Securities Act
August 5, 2020 Page 3  or Exchange    Act.
FirstName LastName
 Conn Flanigan
FirstName  LastNameConn
China Foods  Holdings Ltd. Flanigan
Comapany
August     NameChina Foods Holdings Ltd.
       5, 2020
August
Page 4 5, 2020 Page 4
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 Laura Crotty at (202) 551-7614 or Tim Buchmiller at (202)
551-3635 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences