November 20, 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.
           Amendment No. 1 to
           Registration Statement on Form F-1
           Filed November 15, 2019
           File No. 333-234408

Dear Dr. Yu:

      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 November 12,
2019 letter.

Form F-1/A filed November 15, 2019

Dilution, page 61

1.     Your disclosure of pro forma net tangible book value US$11.2 million
after giving effect
       to the offering does not appear to reconcile with the net tangible book
value of (US$6.6
       million) plus the net proceeds of US$16.9 million disclosed on page 58.
Please clarify or
       revise.
 Chris Chang Yu
AnPac Bio-Medical Science Co., Ltd.
November 20, 2019
Page 2
Description of Share Capital
Ordinary Shares, page 161

2.    On September 17, 2019, you issued 214,000 shares for $3.27 per share to
your founder
      and chairman. On October 25, 2019, you issued 769,000 shares for $0.01
per share to
      YuLin Bio-medical as result of certain PRC shareholders restructuring
their
      shareholding. Please tell us in greater detail the nature and terms of
each issuance, how
      you determined the fair value (if applicable), how you accounted for any
difference
      between fair value and the cash consideration received and the accounting
literature you
      relied upon. Also, disclose more information about the nature and terms
of each issuance
      in the filing, including the interim financial statement footnotes.
Consolidated Financial Statements for the Year Ended December 31, 2018
Notes to the Consolidated Financial Statements
12. Share Based Compensation, page F-30

3.    We have reviewed your response to comment 2 noting it appears the stock
options were
      not adjusted to reflect the 1-for-100 share split. Please revise your
disclosures here and
      elsewhere in the filing, such as Note 10 to your interim financial
statements and page 87,
      or tell us why your current presentation is appropriate. Refer to SAB
Topic 4:C.
       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 20, 2019 Page 2
cc:       Shuang Zhao
FirstName LastName