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                             April 7, 2022

       Suqin Li
       Chief Executive Officer
       Majestic Ideal Holdings Ltd
       22/F, China United Plaza
       1002-1008, Tai Nan West Street
       Cheung Sha Wan, Kowloon, Hong Kong

                                                        Re: Majestic Ideal
Holdings Ltd
                                                            Amendment No. 3 to
Draft Registration Statement on Form F-1
                                                            Submitted March 17,
2022
                                                            CIK No. 0001897532

       Dear Ms. Li:

             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. 3 to Draft Registration Statement on Form F-1 submitted
March 17, 2022

       Cover Page

   1.                                                   Please clarify the
amount of your cash that is in RMB and Hong Kong dollars. Please
                                                        disclose whether cash
generated from one subsidiary is used to fund another subsidiary's
                                                        operations, whether
your subsidiaries have ever faced difficulties or limitations on their
                                                        ability to transfer
cash between subsidiaries, and whether your subsidiaries have cash
                                                        management policies
that dictate the amount of such funding. Also, disclose whether your
                                                        subsidiaries have cash
management policies/procedures that dictate how funds are
                                                        transferred. Your
disclosure should address the possibility that the PRC could prevent the
                                                        cash maintained in the
PRC or Hong Kong from leaving, or that the PRC could restrict
 Suqin Li
FirstName   LastNameSuqin
Majestic Ideal  Holdings LtdLi
Comapany
April       NameMajestic Ideal Holdings Ltd
       7, 2022
April 27, 2022 Page 2
Page
FirstName LastName
         deployment of the cash into the business or for the payment of
dividends. Add similar
         disclosure to risk factors and to the summary of risk factors.
Risks Relating to Doing Business in China, page 5

2.       Please revise the disclosure in the first bullet point to specifically
discuss risks arising
         from the legal system in China, including risks and uncertainties
regarding the
         enforcement of laws and that rules and regulations in China can change
quickly with little
         advance notice, which could result in a material change in your
operations and/or the
         value of the securities you are registering for sale.
3.       Please revise the disclosure in the second bullet point in this
section to clarify that
         the PRC government may intervene or influence your operations at any
time, or may exert
         more control over offerings conducted overseas and/or foreign
investment in China-
         based issuers, which could result in a material change in your
operations and/or the value
         of the securities you are registering for sale.
4.       Please revise the disclosure in the first sentence of the last bullet
point on page 5 to
         acknowledge any risks that any actions by the Chinese government to
exert more
         oversight and control over offerings that are conducted overseas
and/or foreign investment
         in China-based issuers could significantly limit or completely hinder
your ability to offer
         or continue to offer securities to investors and cause the value of
such securities to
         significantly decline or be worthless.
Recent Regulatory Developments in China, page 9

5.       We note your disclosure about the revised draft released on July 10,
2021. Please update
         your disclosures in this section and elsewhere in your filing to
reflect that: (1) the
         Cyberspace Administration of China issued the New Measures for
Cybersecurity Review
         on January 4, 2022; (2) that the New Measures amended the Measures for
Cybersecurity
         Review released on July 10, 2021; and (3) the New Measures came into
effect on
         February 15, 2022. Generally, please ensure that your discussion of
PRC laws, rules and
         regulations is current.
Recent joint statement by the SEC and the PCAOB, page 17

6.       We note your disclosure about the Holding Foreign Companies
Accountable Act. Please
         revise the disclosure to clarify that the United States Senate has
passed the Accelerating
         Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the
         number of non-inspection years    from three years to two years, and
thus, would reduce
         the time before your securities may be prohibited from trading or
delisted. Update your
         disclosure to reflect that the Commission adopted rules to implement
the HFCAA and that,
         pursuant to the HFCAA, the PCAOB has issued its report notifying the
Commission of its
         determination that it is unable to inspect or investigate completely
accounting firms
         headquartered in mainland China or Hong Kong.
 Suqin Li
Majestic Ideal Holdings Ltd
April 7, 2022
Page 3
In light of recent events indicating greater oversight, page 19

7.     Please revise the disclosure in this risk factor to explain how this
oversight impacts your
       business and your offering. Regarding the disclosure on page 19 about
your belief that
       you "are neither currently impacted nor covered by the permission and
requirements from
       the CSRC or CAC," please revise to clarify whether you obtained an
opinion of counsel
       regarding required approvals from the CSRC or CAC. If you did obtain an
opinion of
       counsel, please file the consents as exhibits.
Enforceability of Civil Liabilities, page 114

8.     We note the disclosure on pages 83-84 about your officers and directors.
Please revise the
       disclosure on page 114 to discuss, if applicable, the extent to which
your directors and
       officers are nationals or residents of the PRC and revise the Risk
Factors section to
       include a separate risk factor to highlight the risk discussed on page
114.
General

9.     Please remove the Filing Fee Table from the cover page and file it as an
exhibit to this
       registration statement. Refer to Item 601(b)(107) of Regulation S-K.
        You may contact Heather Clark, Staff Accountant, at 202-551-3624 or
Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding
comments on the
financial statements and related matters. Please contact Thomas Jones, Staff
Attorney, at 202-
551-3602 or Jay Ingram. Legal Branch Chief, at 202-551-3397 with any other
questions.



                                                              Sincerely,
FirstName LastNameSuqin Li
                                                              Division of
Corporation Finance
Comapany NameMajestic Ideal Holdings Ltd
                                                              Office of
Manufacturing
April 7, 2022 Page 3
cc:       Virginia Tam
FirstName LastName