December 23, 2019

Martyn Wade
Chief Executive Officer
Grindrod Shipping Holdings Ltd.
#03-01 Southpoint
200 Cantonment Road
Singapore 089763

       Re: Grindrod Shipping Holdings Ltd.
           Form 20-F for the Fiscal Year ended December 31, 2018
           Filed April 16, 2019
           File No. 001-38440

Dear Mr. Wade:

       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, 2018

Operating and Financial Review and Prospects, page 46

1.    We note that voyage expenses include several significant categories, such
as pool
      distributions, fuel costs, port expenses, and forward freight agreement
derivatives.
      However, expenses for certain categories are not quantified. Please
expand your
      disclosure to address changes in the material components of voyage
expenses, in dollars
      and percentages, to more clearly focus your narrative on the underlying
variances.
2.    Please discuss any known trends or uncertainties that are reasonably
likely to have a
      material effect on your profitability, such as the recent change in
regulations requiring a
      reduction in sulfur emissions, from 3.5% of fuel content to 0.5%, which
you indicate on
      page 39 could have a material negative impact on your results.
 Martyn Wade
FirstName LastNameMartyn Ltd.
Grindrod Shipping Holdings Wade
Comapany23, 2019
December NameGrindrod Shipping Holdings Ltd.
December 23, 2019 Page 2
Page 2
FirstName LastName
         For example, quantifying the volumes of fuel consumed in ship
operations each period as
         well as average fuel costs, and providing either your anticipated
change in fuel costs or a
         sensitivity analysis, may suffice. Please refer to Part I, Item 5.A
and 5.D of Form 20-F, if
         you require further clarification or guidance.
Financial Statements
Consolidated and Combined Statements of Cash Flows, page F-6

3.       We note that you report proceeds from the disposal of ships as revenue
and the cost of
         ships sold as a cost of sales in your Statements of Profits or Loss,
presumably with
         reliance on paragraph 68A of IAS 16. However, we also see that you
include both capital
         expenditures to acquire ships and proceeds from the disposal of ships
as separate line
         items in the operating section of your Statements of Cash Flows.

         Please clarify how you have applied the guidance in paragraphs 16(a)
and (b) of IAS 7, in
         reporting this activity in the operating section of your Statements of
Cash Flows.
Note 2-Significant Accounting Policies, page F-8

4.       We understand from your disclosures on pages 33 and 34 that you have
vessels operating
         in commercial pools that you manage and in pools that are managed by
others. Please
         include an accounting policy disclosure that reflects your
consideration of the guidance in
         paragraphs B34 through B38 of IFRS 15, regarding your principal versus
agent and gross
         versus net presentation determinations, and indicate how you report
your allocations of
         amounts attributable to participants in pools for which you are the
manager/principal.

         Please describe the scope of your responsibilities for these pools,
also the composition of
         the vessels managed in each pool, duration of the agreements, and
extent of your
         economic interests or the number of your ships in the pools in
relation to ships owned by
         others. Tell us the amounts of the revenues and expenses that you
report for each period
         that relate to pool agreements in which you were the
manager/principal, and the amounts
         of such revenues and expenses retained based on your share of the
pools.

         If you have vessel pool arrangements that you manage but are
accounting for as an agent,
         please provide the analyses that you performed in formulating your
accounting policy and
         please submit copies of the vessel pool agreements that were the most
significant during
         2018, in your role as a manager/principal, manager/agent, and
non-manager/agent.
       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.
 Martyn Wade
Grindrod Shipping Holdings Ltd.
December 23, 2019
Page 3

       You may contact John Cannarella, Staff Accountant at (202) 551-3337 or
Jenifer
Gallagher, Staff Accountant at (202) 551-3706 with any questions.



FirstName LastNameMartyn Wade                            Sincerely,
Comapany NameGrindrod Shipping Holdings Ltd.
                                                         Division of
Corporation Finance
December 23, 2019 Page 3                                 Office of Energy &
Transportation
FirstName LastName