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                              December 5, 2022

       Long Chen
       Chief Executive Officer
       ZKH Group Limited
       7/F, Tower 4, Libao Plaza, No. 36 Shenbin Road
       Minhang District, Shanghai 201106
       People   s Republic of China

                                                        Re: ZKH Group Limited
                                                            Amendment No. 5 to
Draft Registration Statement on Form F-1
                                                            Submitted November
22, 2022
                                                            CIK No. 0001862044

       Dear Long Chen:

             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. 5 to Draft Registration Statement on Form F-1

       Cover Page

   1.                                                   Please amend your
disclosure here and in the summary risk factors and risk factors
                                                        sections to state that,
to the extent cash or assets in the business is in the PRC/Hong Kong
                                                        or a PRC/Hong Kong
entity, the funds and assets may not be available to fund operations
                                                        or for other use
outside of the PRC/Hong Kong due to interventions in or the imposition
                                                        of restrictions and
limitations on the ability of you or your subsidiaries by the PRC
                                                        government to transfer
cash or assets.
 Long Chen
FirstName
ZKH GroupLastNameLong    Chen
            Limited
Comapany5,
December  NameZKH
             2022    Group Limited
December
Page 2    5, 2022 Page 2
FirstName LastName
Conventions that Apply to this Prospectus, page ii

2.       We note your definition of    China    excludes Hong Kong and Macau,
yet it appears you
         have subsidiaries located in Hong Kong. Please revise to clarify that
the legal and
         operational risks associated with operating in China also apply to
operations in Hong
         Kong and Macau. Revise in the definition itself or in an appropriate
discussion of legal
         and operational risks.
Critical Accounting Estimates
Fair Value of Our Ordinary Shares and Valuation of Our Ordinary Shares, page
111

3.       Once you have an estimated offering price or range, please provide us
with an analysis
         explaining the reasons for the differences between the recent
valuations of your common
         stock leading up to the initial public offering and the estimated
offering price. This
         information will help facilitate our review of your accounting for
equity issuances
         including stock compensation and beneficial conversion features.
General

4.       Where you discuss the August 26, 2022 Statement of Protocol throughout
your filing,
         revise to state that the PCAOB will be required to reassess its
determinations by the end of
         2022.
5.       Revise your filing to discuss the applicable laws and regulations in
Hong Kong and/or
         Macau, as applicable, as well as the related risks and consequences,
including, but not
         limited to, the enforceability of civil liabilities in Hong Kong/Macau
in your risk factors
         and Enforceability section on page 88, how regulatory actions related
to data security or
         anti-monopoly concerns in Hong Kong/Macau have or may impact the
company   s ability
         to conduct its business, accept foreign investment or list on a
U.S./foreign exchange on
         your cover page and prospectus summary, and whether there are
laws/regulations in Hong
         Kong/Macau that result in oversight over data security, how this
oversight impacts the
         company   s business and the offering, and to what extent you believe
that you are
         compliant with the regulations or policies that have been issued in
your risk factors.
       You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Donald Field at 202-551-3680 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services