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                               September 15, 2022

       Huiping Yan
       Chief Financial Officer
       ZTO Express (Cayman) Inc.
       Building One, No. 1685 Huazhi Road
       Qingpu District, Shanghai 201708
       People's Republic of China

                                                        Re: ZTO Express
(Cayman) Inc.
                                                            Form 20-F for the
Fiscal Year ended December 31, 2021
                                                            Filed April 28,
2022
                                                            File No. 001-37922

       Dear Ms. Yan:

              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 20-F for the Fiscal Year ended December 31, 2021

       Introduction, page 1

   1.                                                   We note your disclosure
on page 3 indicating that terms such as    we,       us,       our
                                                        company    or    our
refer to ZTO Express (Cayman) Inc. and its subsidiaries, although
                                                        when describing your
operations and the consolidated financial information, you are using
                                                        these same terms to
refer to the consolidated variable interest entity (VIE) and the
                                                        subsidiaries of the
consolidated VIE in China, including but not limited to ZTO Express.

                                                        Please revise
disclosures throughout your filing as necessary to provide distinct references
                                                        for the holding company
and its subsidiaries, and separately for the VIE and its
                                                        subsidiaries, so that
it is clear to investors which entities the disclosures are referencing,
                                                        and which subsidiaries
or entities are conducting the business operations.
 Huiping Yan
ZTO Express (Cayman) Inc.
September 15, 2022
Page 2
         Given that you do not have a controlling ownership interest in the
VIE, please refrain
         from using terms such as    we,       us,       our company    and
our    when describing
         operations and the consolidated financial information of the VIE.

         Also revise the organizational chart on page 6 to label the VIE and to
identify the
         subsidiaries of the VIE that are referenced in your disclosure on page
3.
Key Information, page 11
Financial Information related to ZTO Express, page 14

2.       We note that you present condensed consolidating statements on pages
14, 15 and 16,
         although limit details in the Balance Sheet data to assets and
liabilities, and limit details in
         the Statements of Operations data to revenue and net income.

         Please revise your tabulations in an amendment to your filing to
include the equity
         accounts for the entities and to present additional details for the
Statements of Operations,
         commensurate with the guidance on condensed financial information of
the parent in
         Schedule I of Rule 5-04(c) of Regulation S-X, also as utilized in
preparing consolidated
         Statements of Operations under Rule 10-01(a)(3), with reference to the
guidance in Rule
         5-03(b) of Regulation S-X, though also including the interests of the
parent in earnings of
         your subsidiaries, and the interests of your subsidiaries in earnings
of the VIE.

         Also revise the header to these tabulations from "Financial
Information Related to ZTO
         Express" to "Condensed Consolidating Financial Information of ZTO
Express (Cayman)
         Inc.," or similar language to more clearly convey the scope of the
presentation, and revise
         the "ZTO Express" columnar headers to use "VIE" or "VIE and
subsidiaries," either
         incrementally to, or in lieu of, the current labels, as appropriate.
        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 Lily Dang at (202) 551-3867 or John Cannarella at (202)
551-3337 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Karl Hiller - Branch Chief at (202) 551-3686 with any other questions.



FirstName LastNameHuiping Yan                                    Sincerely,
Comapany NameZTO Express (Cayman) Inc.
                                                                 Division of
Corporation Finance
September 15, 2022 Page 2                                        Office of
Energy & Transportation
FirstName LastName