November 12, 2019

Chris Chang Yu
Chief Executive Officer
AnPac Bio-Medical Science Co., Ltd.
801 Bixing Street, Bihu County
Lishui, Zhejiang Province 323006
People's Republic of China

       Re: AnPac Bio-Medical Science Co., Ltd.
           Registration Statement on Form F-1
           Filed October 31, 2019
           File No. 333-234408

Dear Dr. Yu:

       We have reviewed your 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.

Registration Statement on F-1 filed October 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Components of Results of Operations
Revenues, page 72

1.     Please retitle the measure you call gross revenue from physical checkup
packages, so it is
       not referred to as being revenue. Also, disclose how the measure is
relevant to
       understanding your results of operations and why it is important to
investors.
 Chris Chang Yu
AnPac Bio-Medical Science Co., Ltd.
November 12, 2019
Page 2
Unaudited Interim Condensed Financial Statements for the Nine Months Ended
September 30,
2019
Notes to the Unaudited Interim Condensed Consolidated Financial Statements
2. Summary of Principal Accounting Policies
(f) Unaudited pro forma shareholder's deficit and loss per share , page F-52

2.    Please present the 1-for-100 share split that occurred on October 31,
2019 retroactively in
      your financial statements for all periods presented, including any share
amounts presented
      in the forepart of the document, or tell us why your current presentation
is appropriate.
      Refer to SAB Topic 4:C.
Exhibits

3.    We note that exhibit 5.1 states that the opinion "may not be relied upon
by any other
      person for any purpose." Please revise. For guidance, see Section
II.B.3.d of Staff Legal
      Bulletin No. 19 (CF).
4.    Please delete the qualification "[e]xcept as disclosed in the
registration statement" in
      paragraph 5(1) of Exhibit 99.2 and replace this language with a
substantive discussion.
      Additionally, please make clear the extent that this opinion and the risk
factors in the
      registration statement encompass the new Foreign Investment Law that will
come into
      effect in the near future.
        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.

       You may contact Angela Lumley at 202-551-3398 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jonathan Burr at 202-551-5833 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                            Sincerely,
FirstName LastNameChris Chang Yu
                                                            Division of
Corporation Finance
Comapany NameAnPac Bio-Medical Science Co., Ltd.
                                                            Office of Real
Estate & Construction
November 12, 2019 Page 2
cc:       Shuang Zhao
FirstName LastName