August 29, 2019

Jinlong Yang
Chief Executive Officer
MingZhu Logistics Holdings Ltd
27F, Yantian Modern Industry Service Center
No. 3018 Shayan Road, Yantian District
Shenzhen, Guangdong, China 518081

       Re: MingZhu Logistics Holdings Ltd
           Draft Registration Statement on Form F-1
           Submitted August 2, 2019
           CIK No. 0001782037

Dear Mr. Yang:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement Submitted August 2, 2019

General

1.     Please provide us copies of all written communications, as defined in
Rule 405 under the
       Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential
       investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain
       copies of the communications.
Risk Factors
Our reliance on major customers and any loss of our major customers, page 7

2.     Please place the risks described in context by naming each ten percent
or greater customer
 Jinlong Yang
FirstNameLogistics Holdings Yang
MingZhu LastNameJinlong Ltd
Comapany NameMingZhu Logistics Holdings Ltd
August 29, 2019
August 29, 2019 Page 2
Page 2
FirstName LastName
         and the respective percentage of revenues attributable to that
customer.
We rely on subcontractors to handle a proportion of our trucking service, page
8

3.       To the extent material, please describe the risks because of your
guarantee of the
         subcontractor capital lease disclosed on page 42.
Use of Proceeds, page 30

4.       You state that PRC laws and regulations limit your ability to utilize
the proceeds of this
         offering to make loans or capital contributions to PRC subsidiaries on
satisfaction of
         government registration and approval requirements. Please place this
disclosure in
         context by quantifying the amount of loans or capital contributions
you may currently
         make to your PRC subsidiaries without approval. Similarly revise the
first full risk factor
         on page 20.
Management's Discussion and Analysis, page 35

5.       Please provide the trend disclosure required by Item 5.D of Form 20-F.
For guidance,
         refer to Section III.B.3. of Release No. 33-8350. We note by way of
example: (i) the
         second paragraph on page 38 where you discuss reasons for the decline
in revenues from
         Guangdong province; and (ii) your disclosure in the third risk factor
on page 7 and first
         risk factor on page 8 regarding past due receivables and the timing
mismatch of customer
         payments and trade payables. Also discuss the extent to which
percentage growth you
         attribute to the Xinjiang expansion is indicative of future growth.
Customers, page 65

6.       Please describe the material terms of the master agreements you enter
into with
         customers. Similarly describe in the last section on page 67 the
material terms of the
         subcontracting master agreements.
Regulations, page 74

7.       Please discuss here the PRC regulations on and approvals required for
uses of proceeds
         from offerings such as this, including the regulations on loans or
capital contributions to
         your PRC subsidiaries. We note your disclosure in the last paragraph
on page 30.
Description of Share Capital
Articles of Association   Exclusive Forum Provision, page 89

8.       We note that your forum selection provision identifies the courts of
the Cayman Islands as
         the sole and exclusive jurisdiction for certain litigation, including
"any derivative action."
         Please disclose whether this provision applies to actions arising
under the Securities Act
         or Exchange Act. If so, please add risk factor disclosure, state that
there is uncertainty as
         to whether a court would enforce such provision, and state that
investors cannot waive
 Jinlong Yang
MingZhu Logistics Holdings Ltd
August 29, 2019
Page 3
      compliance with the federal securities laws and the rules and regulations
thereunder. If
      this provision does not apply to actions arising under the Securities Act
or Exchange Act,
      please also ensure that the exclusive forum provision in your amended
articles of
      association states this clearly, or tell us how you will inform investors
in future filings that
      the provision does not apply to any actions arising under the Securities
Act or Exchange
      Act.
        You may contact Amy Geddes, Staff Accountant, at (202) 551-3304 or Lyn
Shenk,
Accounting Branch Chief, at (202) 551-3380 if you have questions regarding
comments on the
financial statements and related matters. Please contact J. Nolan McWilliams,
Attorney-Advisor,
at (202) 551-3217 or Laura Nicholson, Special Counsel, at (202) 551-3549 with
any other
questions.



                                                              Sincerely,
FirstName LastNameJinlong Yang
                                                              Division of
Corporation Finance
Comapany NameMingZhu Logistics Holdings Ltd
                                                              Office of
Transportation and Leisure
August 29, 2019 Page 3
cc:       Sabrina He
FirstName LastName