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                              September 12, 2023

       Weilai Zhang
       Chief Executive Officer
       Antelope Enterprise Holdings Ltd
       Room 1802, Block D, Zhonghai International Center
       Hi-Tech Zone, Chengdu
       Sichuan Province, PRC

                                                        Re: Antelope Enterprise
Holdings Ltd
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-34944

       Dear Weilai Zhang:

              We have reviewed your August 17, 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.

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

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 82

   1.                                                   We note your statement
that you reviewed your register of members and 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).
 Weilai Zhang
FirstName LastNameWeilai
Antelope Enterprise HoldingsZhang
                             Ltd
Comapany 12,
September NameAntelope
              2023        Enterprise Holdings Ltd
September
Page 2    12, 2023 Page 2
FirstName LastName
2.       We note that your disclosures pursuant to Items 16I(b)(2), (b)(3),
(b)(4), and (b)(5) are
         provided for "our company.    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.
             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.       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.
4.       With respect to your disclosure pursuant to Item 16I(b)(5), we 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.
       Please contact Kyle Wiley at (202) 344-5791 or Andrew Mew at (202)
551-3377 with
any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Disclosure Review
Program
cc:      Joan Wu