December 9, 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. 2 to
           Registration Statement on Form F-1
           Filed December 5, 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 20,
2019 letter.

Form F-1/A filed December 5, 2019

Capitalization, page 61

1.     Please disclose the number of shares issued and outstanding on an
actual, pro forma and
       pro forma as adjusted basis.
Interim Financial Statements
Interim Statements of Changes in Shareholders' Equity (Deficit), page F-47

2.     We read your response to comment 2. The cancelled and reissued shares
appear to be
       material to the number of shares outstanding as of September 30, 2019.
Please tell us and
 Chris Chang Yu
AnPac Bio-Medical Science Co., Ltd.
December 9, 2019
Page 2
      disclose the timing and terms associated with the repurchase and
cancellation of 1,574,700
      shares during the nine months ended September 30, 2019, including any
promises to
      reissue shares at a later date. Also, explain, with reference to the GAAP
literature you
      relied upon, how you determined that none of the shareholders whose
shares were
      cancelled had rights to common stock or potential common stock as of
September 30,
      2019, despite a significant portion of these cancelled shares being later
reissued for no
      additional consideration. If some or all of these shares or potential
shares, should be
      reflected in your September 30, 2019 interim financial statements, please
make the
      appropriate revisions here and elsewhere in the filing, such as in the
capitalization and
      dilution sections. Refer to ASC 260-10-20, ASC 505-10-45 and ASC
505-10-50.
       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
December 9, 2019 Page 2
cc:       Shuang Zhao
FirstName LastName