March 15, 2018

Feng Zhou
Chief Executive Officer
China SXT Pharmaceuticals, Inc.
178 Taidong Rd North, Taizhou
Jiangsu, China

       Re: China SXT Pharmaceuticals, Inc.
           Amendment No. 2 to Registration Statement on Form F-1
           Filed March 6, 2018
           File No. 333-221899

Dear Mr. Zhou:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our February 4,
2018 letter.

Amendment No. 2 to Registration Statement on Form F-1

Capitalization, page 35

1.     Please update the financial statement information at the Summary
Financial Data (page
       13), Capitalization Table (page 35), and Dilution Table (page 37) for
consistency with the
       interim period financial statements included in the filing. Refer to the
Instructions for Item
       3 of Form 20-F.
 Feng Zhou
FirstName LastNameFeng Zhou
China SXT Pharmaceuticals, Inc.
Comapany2018
March 15, NameChina SXT Pharmaceuticals, Inc.
Page 2
June 16, 2017 Page 2
FirstName LastName
Business, page 47

2.       We note your response to prior comment 10, which appears inconsistent
with your
         disclosures throughout the Prospectus Summary, Business section, and
elsewhere that
         implies you are developing new products that give you an edge over
major
         competitors. For example:
           On page 8, you indicate your belief that your research and
development capabilities
             allow you to create innovative TCMP that fulfills your customers'
needs;
           On page 53, you disclose you expect to continue to gain additional
competitive
             advantages through the growing pipeline of new TCMP products;
           On pages 8, 40, 43 and 59, you disclose you are constantly in the
process of
             developing new types of advanced TCMP products; and
           On pages 40, 41, and 43 you imply the company has identified great
advantages of
             advanced TCMP over regular TCMP.
         Please revise these disclosures and throughout your filing to clearly
indicate that your
         research and development, if true, is primarily focused on innovative
engineering methods
         for cleaning and grinding traditional TCMPs and that your working
process has not
         produced a new medicine or changed the medicinal effects of TCMPs,
consistent with
         your response.
Share Pledge Agreement, page 50

3.       We reissue prior comment number 7. Please specify to dollar amount of
the payment due
         under the Share Pledge Agreement.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(i) Accounts Receivables, page F-41

4.       We acknowledge your response to prior comment 12. As previously
requested, please
         revise to include the information in your response explaining why DSO
is so high in your
         filing. Further, we note the accounts receivable balances that are
included in the table in
         your response do not agree to the accounts receivable balances
included in your December
         31, 2017 financial statements (see page F-30). Please explain this
discrepancy and as
         necessary, provide us an updated aging.
 Feng Zhou
China SXT Pharmaceuticals, Inc.
March 15, 2018
Page 3

       You may contact Christine Torney at 202-551-3652 or Sharon Blume at
202-551-3474 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Chris Edwards at 202-551-6761 or Mary Beth Breslin at 202-551-3625 with
any other
questions.


FirstName LastNameFeng Zhou
                                                          Division of
Corporation Finance
Comapany NameChina SXT Pharmaceuticals, Inc.
                                                          Office of Healthcare
& Insurance
June 16, 2017 Page 3
cc: Joan Wu
FirstName LastName