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                             January 12, 2021

       Eli Glickman
       Chief Executive Officer and President
       ZIM Integrated Shipping Services Ltd.
       9 Andrei Sakharov Street
       P.O. Box 15067
       Matam, Haifa 3190500, Israel

                                                        Re: ZIM Integrated
Shipping Services Ltd.
                                                            Registration
Statement on Form F-1
                                                            Filed December 30,
2020
                                                            File No. 333-251822

       Dear Mr. Glickman:

              We have reviewed your registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1

       Recent Developments
       Preliminary estimated unaudited financial and operating results as of
and for the fiscal year
       ended December 31, 2020, page 7

   1.                                                   We note your proposed
disclosure of preliminary financial results as of and for the year
                                                        ended December 31,
2020, and the anticipated disclosure of a low and high range for cash
                                                        and cash equivalents,
long-term debt, income from voyages and related services, net
                                                        income (loss), adjusted
EBIT, adjusted EBITDA, TEUs carried, average freight per TEU
                                                        carried and freight
revenues from containerized cargo. Please note that when a range is
                                                        presented for the
foregoing financial data rather than a specific number, the range should
                                                        be sufficiently narrow
to be meaningful, and you should explain why you are not able to
 Eli Glickman
FirstName  LastNameEli
ZIM Integrated ShippingGlickman
                        Services Ltd.
Comapany
January 12,NameZIM
            2021     Integrated Shipping Services Ltd.
January
Page 2 12, 2021 Page 2
FirstName LastName
         disclose an exact number.

         Your presentation of preliminary results should include sufficient
narrative disclosure to
         provide appropriate context. In this regard, you should provide your
analysis of the
         preliminary results so that investors can understand what they mean.
For example,
         indicate whether the preliminary results are consistent with the trend
disclosure in
         Management   s Discussion and Analysis of Financial Condition and
Results of Operations
         and whether other significant income statement line items reflect
similar trends.
Risk factors
Our dividend policy is subject to change at the discretion of our Board of
Directors, page 40

2.       You disclose that your Board of Directors has adopted a dividend
policy, which will be in
         effect following the offering, to distribute each year up to 50% of
your annual net income
         as determined under IFRS, subject to applicable law and other factors.
Please revise this
         risk factor to specifically disclose the limitations on your ability
to pay dividends under
         your existing indebtedness, and any future indebtedness you may incur.
We note your
         disclosure at page 46 which states that your existing indebtedness
permits you to pay
         dividends (i) in an amount per year of up to 5% of the proceeds you
receive from any
         public equity offering (not including this offering) and (ii) in an
amount that does not
         exceed 50% of your cumulative net income, minus any amounts paid
pursuant to clause
         (i). Additionally, please clarify that the distribution amount may be
limited pursuant to
         the Companies Law.
Dividend Policy, page 46

3.       Please disclose whether your dividend policy will be reflected in any
written policies of
         the company.
Compensation of officers and directors, page 145

4.       Please revise to provide your executive compensation disclosure for
your most recent
         completed fiscal year. See Item 4 to Form F-1; Item 6.B. of Form 20-F.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      You may contact Yolanda Guobadia, Staff Accountant, at 202-551-3562 or
Gus
Rodriguez, Accounting Branch Chief, at 202-551-3752 if you have questions
regarding
comments on the financial statements and related matters. Please contact Irene
Barberena-
 Eli Glickman
ZIM Integrated Shipping Services Ltd.
January 12, 2021
Page 3

Meissner, Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen, Legal Branch
Chief, at 202-
551-3642 with any other questions.



                                                         Sincerely,
FirstName LastNameEli Glickman
                                                         Division of
Corporation Finance
Comapany NameZIM Integrated Shipping Services Ltd.
                                                         Office of Energy &
Transportation
January 12, 2021 Page 3
cc:       Pedro J. Bermeo, Esq.
FirstName LastName