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                             April 8, 2022

       Yin-Chieh Cheng
       President and Chief Executive Officer
       Nocera, Inc.
       3F (Building B), No. 185, Sec. 1, Datong Rd.,
       Xizhi Dist., New Taipei City
       221, Taiwan

                                                        Re: Nocera, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed April 1, 2022
                                                            File No. 333-264059

       Dear Mr. Cheng:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form S-1 filed April 1, 2022

       Cover Page

   1.                                                   We note your revised
disclosures in response to prior comment 1. You state that you have
                                                        been provisionally
identified by the SEC as an issuer under the HFCAA and that you
                                                        intend to respond to
the SEC by April 20, 2022 to submit support that you should be
                                                        removed from this list.
Please explain to us the type of evidentiary support you intend to
                                                        submit.
       Prospectus Summary, page 1

   2.                                                   You state on page 2
that your Chinese subsidiary, Guizhou Grand Smooth Technology
                                                        Ltd., may be involved
with RASs manufacturing in the "near future". You also state
 Yin-Chieh Cheng
Nocera, Inc.
April 8, 2022
Page 2
      on page F-22 that you plan to reinvest your earnings to "potentially
continue" business in
      mainland China, and we note your new risk factor on page 21 refers to the
uncertainties of
      operating in China. Please reconcile these statements with your
disclosure on page 1
      claiming you do not currently have any intentions of conducting
operations in China or
      Hong Kong. If you are contemplating to operate in either Hong Kong or
China, please
      revise your disclosures to detail such plans.
Holding Foreign Companies Accountable Act, page 4

3.    We acknowledge your revised disclosures in response to prior comment 2
and refer to
      your statement that if you do not engage an auditor that is subject to
regular inspection by
      the PCAOB, your securities "may" be prohibited from a U.S. securities
exchange or OTC
      trading market. Please revise to explain the conditions that would lead
to your securities
      being delisted and prohibited from a U.S. securities exchange or OTC
trading market.
      Please correspondingly revise the twelfth bullet on page 6 and your new
risk factor
      starting on page 18. With respect to your new risk factor starting on
page 18, please also
      revise to make sure it is up-to-date and specific to you.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Tyler Howes at 202-551-3370 or Dorrie Yale at
202-551-8776 with
any questions.



                                                            Sincerely,
FirstName LastNameYin-Chieh Cheng
                                                            Division of
Corporation Finance
Comapany NameNocera, Inc.
                                                            Office of Life
Sciences
April 8, 2022 Page 2
cc:       Philip Magri, Esq.
FirstName LastName