August 27, 2024

Jian Hua
Chief Executive Officer
Papa Medical Inc.
202 North California Ave
City of Industry, CA 91744

       Re: Papa Medical Inc.
           Draft Registration Statement on Form S-1
           Submitted July 31, 2024
           CIK No. 0002024283
Dear Jian Hua:

       We have reviewed your draft registration statement and have the
following comment(s).

        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 a comment applies 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 this letter
and your amended
draft registration statement or filed registration statement, we may have
additional comments.

Draft Registration Statement on Form S-1 filed July 31, 2024
Risk Factors, page 7

1.     We note your disclosure throughout this registration statement stating
that Mr. Jian Hua,
       your chief executive officer and director, holds 83.6% of your common
stock and
       that Papa Medical Inc. or its subsidiaries/operating companies have
entered into
       agreements with other entities that are either owned by or have an
ownership interest in
       by Mr. Hua   including rental agreements and supplier relationships etc.
Please discuss in
       a separate risk factor the risks posed by this arrangement. Specifically
discuss whether
       other entities without an affiliation with Mr. Hua were considered when
considering
       potential leased properties and suppliers. Also discuss whether prices
paid to entities that
       are affiliated with Mr. Hua such as lease rates and inventory/supplies
prices are in line
       with market rates of other non-affiliated entities.
 August 27, 2024
Page 2
Our business may be impacted by supply chain issues..., page 13

2.     We note your risk factor that your supply chain may be impacted by port
delays. Update
       your risks characterized as potential if recent supply chain disruptions
that are not limited
       to port delays have impacted your operations.
Outbreaks of infectious diseases, epidemics, natural disasters or other events
have materially and
adversely affected..., page 13

3.     We note your disclosure stating that you "carefully evaluate potential
outcomes and work
       to mitigate risks" related to inflation and other macroeconomic risks.
Please update your
       disclosure to identify actions planned or taken, if any, to mitigate
inflationary pressures.
Substantially all of our executive officers and directors are located in
mainland China..., page 15

4.     We note your disclosure stating that except for your Chief Financial
Officer and Chief
       Operating Officer, all of your executive officers and directors are
located in mainland
       China. Please revise your risk factors section to discuss any potential
risks related to PRC
       government regulations. Specifically, discuss whether you are subject
to, or potentially
       could be subject to PRC regulations including but not limited to, CSRC's
Trial
       Administrative Measures. If you believe that you are not subject to
these regulations,
       provide your analysis as to why.
Certain Relationships and Related Party Transactions
Related Party Transactions with Shenzhen Feellife, page 70

5.     We note your disclosure of various agreements with Shenzhen Feellife and
Shenzhen
       LFS, including a purchase agreement for cannibis and consuming E-vapors.
Please
       expand your disclosure to include the purchase amounts paid to these
related parties for
       every period presented. Your current disclosure only provides the amount
of revenue
       generated from your related party transactions.
Financial Statements
General, page F-1

6.     In your next amendment, please provide current interim financial
information and related
       MD&A. Refer to Rules 8-03 and 8-08 of Regulation S-X for guidance.

       Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at
202-551-3629 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Eranga Dias at 202-551-8107 or Jay Ingram at 202-551-3397 with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing