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United States securities and exchange commission logo


                      November 30, 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 completed our review of your filing. 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.


                      Sincerely,


                      Division of Corporation Finance

                      Office of Energy & Transportation
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