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                             August 3, 2023

       Stefan Muehlbauer
       Chief Financial Officer
       Sustainable Projects Group Inc.
       2316 Pine Ridge Road 383
       Naples, Florida 34109

                                                        Re: Sustainable
Projects Group Inc.
                                                            Form 10-K for the
Year Ended December 31, 2022
                                                            Form 10-Q for the
Quarter Ended March 31, 2023
                                                            File No. 000-54875

       Dear Stefan Muehlbauer:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 10-K for the Year Ended December 31, 2022

       Report of Independent Registered Public Accounting Firm, page F-2

   1.                                                   We note the audit
opinion has been dated March 31, 2022, which is prior to the balance
                                                        sheet date. Please
request your auditor update the audit opinion and amend your filing.
       Index to Consolidated Financial Statements
       Note 1. Organization and Nature Operations, page F-8

   2.                                                   We understand that you
have accounted for the Exchange Transaction as a reverse merger
                                                        recapitalization based
on your assessment that Sustainable Projects Group was not a
                                                        business at the time of
transaction. You also state that you have presented your financial
                                                        statements to reflect
the combined operations of Lithium Harvest and Sustainable Projects
                                                        Group as if the merger
transaction occurred on January 1, 2021. Please tell us why you
                                                        believe this
presentation is consistent with the guidance in ASC paragraphs 805-40-45-1
                                                        and 2. In this regard,
we note the financial statements covering periods prior to the
 Stefan Muehlbauer
FirstName
SustainableLastNameStefan   Muehlbauer
            Projects Group Inc.
Comapany
August     NameSustainable Projects Group Inc.
       3, 2023
August
Page 2 3, 2023 Page 2
FirstName LastName
         transaction should correspond to the historical accounts of the
accounting acquirer,
         Lithium Harvest adjusted for the change in capital structure.
Note 9. Intangible Assets, page F-14

3.       We note your intangible assets and goodwill balances at December 31,
2022 were $74,778
         and $156,752, respectively and represent a combined total of 82% of
total assets. From
         your disclosure, it appears these balances are related to the Soy-yer
Dough purchase in
         May 2020. You disclose on page 23 you ended sales of Soy-yer Dough
products in 2021.
         Please address the following:

                Please provide a detailed explanation of your goodwill
impairment analysis,
              including how you considered the ending of sales of the Soy-yer
Dough products
              as an assumption in your analysis. See ASC 350-20-35. Please
revise your
              disclosure to include the required disclosures in accordance with
ASC 350-20-50. In
              addition, to the extent you have performed a quantitative
impairment analysis, your
              disclosure should address whether you are at risk of failing the
quantitative
              impairment test or that the fair value of your reporting unit is
substantially in excess
              of carrying value.

                Please tell us how you considered the ending of sales of these
products as an
              impairment indicator when performing an impairment analysis of
your intangible
              assets in accordance with ASC 350-30-35-14 and ASC 350-30-35-17
through 35-22.
              To the extent you determined no impairment was necessary, please
clearly explain
              the underlying factors that resulted in your conclusion.

                Please explain why your trademark, patents net balance
increased from $593 at
              December 31, 2021 to $10,653 at December 31, 2022. In addition,
you disclose
              trademarks were identified as intangible assets with finite
useful lives, however it
              does not appear you are recording amortization expense on these
assets. Please
              clarify and revise your disclosure, if necessary.

                Please also address how the goodwill and intangible assets were
considered when
              allocating the relative fair value of the assets for the
reorganization transaction with
              Lithium Harvest based on the requirements of ASC 805-50-30-1 and
30-3.

Form 10-Q for the Quarter Ended March 31, 2023

Consolidated Interim Balance Sheets, page F-2

4.       Please tell us why the financial statement amounts reflected for the
year ended December
         31, 2022 in your Form 10-Q for the quarter ended March 31, 2023 do not
agree with the
         corresponding amounts presented in the audited financial statements in
your Form 10-K
         for the year ended December 31, 2022. Clearly explain how you derived
the revised
 Stefan Muehlbauer
Sustainable Projects Group Inc.
August 3, 2023
Page 3
         amounts and why they have been revised. To the extent you have
restated your December
         31, 2022 financial statements due to error, please provide appropriate
disclosures under
         ASC 250 and tell us how you considered the need for amendment of your
Form 10-K for
         the year ended December 31, 2022.
Notes to the Interim Consolidated Financial Statements
Note 8. Reorganization, page F-10

5.       We note on February 14, 2023, you entered into an agreement with
Lithium Harvest and
         the Shareholders to acquire all outstanding shares of capital stock of
Lithium Harvest in
         exchange for issuing to the Shareholders 206,667,233 shares of your
common stock. You
         disclose the Exchange Transaction represents a change of control and
was accounted for
         as a share reorganization with Lithium Harvest being the accounting
acquirer and the
         Company being the accounting acquiree. Please tell us how you
considered ASC 805-40-
         45-2 when presenting the equity balances given Lithium Harvest has
been considered the
         accounting acquirer.
       In closing, 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.

      You may contact Myra Moosariparambil at (202) 551-3796 or Craig Arakawa
at (202)
551-3650 with any questions.



FirstName LastNameStefan Muehlbauer                          Sincerely,
Comapany NameSustainable Projects Group Inc.
                                                             Division of
Corporation Finance
August 3, 2023 Page 3                                        Office of Energy &
Transportation
FirstName LastName