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                           September 8, 2020

       Steven Zhang
       Chief Financial Officer
       MINISO Group Holding Ltd
       25F, Heye Plaza, No.486, Kangwang Middle Road
       Liwan District, Guangzhou 510140, Guangdong Province
       The People   s Republic of China

                                                        Re: MINISO Group
Holding Ltd
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted August
21, 2020
                                                            CIK No. 0001815846

       Dear Mr. Zhang:

             We have reviewed your amended 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.

       Amendment No.1 to Draft Registration Statement on Form F-1 Submitted on
August 21, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Store Network Expansion in China
       Globalization Strategy, page 87

   1.                                                   You disclose increases
in your store network in China and your international store
                                                        expansion through the
MINISO Retail Partner franchisee model and distributors through
                                                        March 31, 2020. Please
update your discussion to reflect the impact of the COVID-19
 Steven Zhang
FirstName LastNameSteven
MINISO Group   Holding LtdZhang
Comapany 8,
September NameMINISO
             2020        Group Holding Ltd
September
Page 2    8, 2020 Page 2
FirstName LastName
         pandemic on the expansion of stores in China and your international
store network.
         Please also comply with this comment on pages 115 and 121. Refer to
Item 303(a)(3)(i)
         through (iii) of Regulation S-K.
Business, page 110

2.       We note your response to prior comment 13. Please rfurther revise to
disclose the other
         material provisions of your franchising agreements such as term and
termination. In
         addition, describe the financial requirements necessary to qualify as
a franchisee and
         whether your competitors provide financing to their franchisees.
Frequently-refreshed Product Assortment with Universal Appeal, page 112

3.       Please revise your disclosure to clarify, as explained in your
response to prior comment
         11, that your co-branding arrangements are not a material source of
your revenue.
Deepen Consumer Engagement and Drive Omni-channel Experience, page 116

4.       We note your supplemental response to prior comment 12 in which you
explain the
         meaning of the term "omni-channel" and state that you do not expect
this strategy to have
         an adverse effect on the profitability of you or your franchisees.
Please revise this section
         to included the information contained in your response.
Product Design Capabilities, page 118

5.       We note your response to prior comment 14. If material, please
quantify the aggregate
         fees paid to Design Academy members, the fixed fee rate and percentage
of sales paid to
         Design Academy team members, the cap on the service fee, the size of
the bonus when
         product performance exceeds a certain threshold, and how the
performance threshold is
         determined.
License Agreement, page 123

6.       We note your response to prior comment 15. Please revise to highlight
the differences
         between the Retail Partner model and the distributor model. In this
regard, we note that
         local distributors have the right to establish MINISO stores in
certain territories. Please
         also clarify your statement that you "license our local distributors
to use our intellectual
         property rights in the licensed territories in a manner pursuant to
the license agreements."
         It is not clear what this disclosure means.
Our Supplier Network, page 124

7.       We note your response to prior comment 16 and re-issue in part. Please
describe the basis
         for your disclosure that your supply chain is best in class. In
addition, please tell us how
         your agreements are structured to be consistent with your philosophy
of maintaining a
         core of 8,000 SKUs and launching 100 new and presumably shorter-lived
SKUs every
         seven days. Lastly, describe the terms of your material agreements
with key suppliers.
 Steven Zhang
MINISO Group Holding Ltd
September 8, 2020
Page 3
Technology Capabilities, page 127

8.    In your response to prior comment 17, you note that certain areas of
store operation are
      standardize while otheres are in the franchisee's discretion. Please
revise your disclosure
      to include the information contained in the second sentence of your
response.
Audited Financial Statements for the Years Ended June 30, 2020 and 2019
Note 2. Significant Accounting Policies
Note 2(f). Inventories, page F-18

9.    We note in your response to comment 22. Please consider revising note
2(f) to clarify the
      responsibilities for absorbing inventory losses by the company and your
franchisees.
       You may contact Robert Shapiro at (202) 551-3273 or Lyn Shenk at (202)
551-3380 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Morris at (202) 551-3314 or Lilyanna Peyser at (202) 551-3222
with any other
questions.



                                                            Sincerely,
FirstName LastNameSteven Zhang
                                                            Division of
Corporation Finance
Comapany NameMINISO Group Holding Ltd
                                                            Office of Trade &
Services
September 8, 2020 Page 3
cc:       Z. Julie Gao
FirstName LastName