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                               September 13, 2023

       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, 2022
                                                            Filed April 20,
2023
                                                            File No. 001-37922

       Dear Huiping Yan:

              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 20-F for the Fiscal Year ended December 31, 2022

       Key Information
       Condensed Consolidating Financial Information of ZTO Express (Cayman)
Inc., page 13

   1.                                                   We note that you have
schedules showing various eliminations made in consolidating the
                                                        results of operations
of your subsidiaries and variable interest entities on pages 17 and 18.

                                                        Please explain to us
your rationale for the disparate intercompany eliminations of revenue
                                                        and cost of revenues in
the schedule for 2022 (i.e. removing RMB 733,687,000 more in
                                                        cost of revenues than
revenues), having the apparent effect of reclassifying cost of
                                                        revenues to other
operating income and enhancing your measure of gross profit.

                                                        Please identify any
changes in circumstances, contractual arrangements, or accounting
                                                        policies underlying
your calculations relative to the preceding two fiscal years.
 Huiping Yan
FirstName LastNameHuiping
ZTO Express (Cayman) Inc. Yan
Comapany 13,
September NameZTO
              2023 Express (Cayman) Inc.
September
Page 2    13, 2023 Page 2
FirstName LastName



Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections,
page 166

2.       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).

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.       We note that your disclosures pursuant to Items 16I(b)(2), (b)(3), and
(b)(5) are provided
         for ZTO Express (Cayman), Inc. or the VIE. We also note from page 6
and your
         list of subsidiaries in Exhibit 8.1 that you have subsidiaries in Hong
Kong and countries
         outside China that are not included in your VIE. 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) and (b)(5), please provide the required
information for you and
              all of your consolidated foreign operating entities in your
supplemental response.

5.       With respect to your disclosure pursuant to Item 16I(b)(5), we note
that you have included
         language that such disclosure is    to our 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.
 Huiping Yan
ZTO Express (Cayman) Inc.
September 13, 2023
Page 3

       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 Robert Babula, Staff Accountant at (202) 551-3339, or
Gus Rodriguez,
Staff Accountant at (202) 551-3752 with any questions. Please contact Austin
Pattan at (202)
551-6756 or Andrew Mew at (202) 551-3377 if you have any questions about
comments related
to your status as a Commission-Identified Issuer during your most recently
completed fiscal year.



FirstName LastNameHuiping Yan                               Sincerely,
Comapany NameZTO Express (Cayman) Inc.
                                                            Division of
Corporation Finance
September 13, 2023 Page 3                                   Office of Energy &
Transportation
FirstName LastName