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                                                           July 10, 2024

Ilan Sobel
Chief Executive Officer
BioHarvest Sciences Inc.
1140-625 Howe Street
Vancouver, BC V6C 2T6, Canada

        Re: BioHarvest Sciences Inc.
            Registration Statement on Form 20-F
            Filed June 14, 2024
            File No. 000-56663
Dear Ilan Sobel:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Registration Statement on Form 20-F
Item 4. Information on the Company
B. Business Overview
Overview, page 22

1.     Please revise your statement on page 22 that you are    focused on
utilizing the Botanical
       Synthesis Platform Technology to develop the next generation of
science-based and
       clinically proven therapeutic solutions    and other statements implying
your nutraceutical
       products may    treat, cure, mitigate or prevent a disease    to remove
any implication that
       your products have been or will be approved or marketed for therapeutic
uses. Please also
       revise your Government Regulations section to disclose how your
cosmeceutical business
       will be regulated in the markets you intend to enter and revise as
appropriate.
2.     Please revise your Business section where appropriate to disclose the
data relied on for
       your statement that you    can produce plant cells with significantly
higher concentrations
       of active ingredients (as compared to those that are produced
naturally), as well as
       extremely high levels of solubility and bio-availability.
 July 10, 2024
Page 2

Products Business Unit, page 23

3.     Please revise page 23 to describe the remaining R&D work related to your
proposed olive
       cell product and to disclose the regulatory approvals needed and what
your clinical trials
       must demonstrate to bring the product to market in the United States and
Israel.
(b) Pharmaceuticals, page 25

4.     Please revise page 25 to disclose for the clinical trials conducted in
the cardio-vascular
       space and the series of promotion studies, the clinical trial designs,
the phase of clinical
       development, the indications, the primary and secondary endpoints,
whether the trials met
       the endpoints, whether the clinical trials were powered for statistical
significance, and if
       so, whether the results were statistically significant, and provide the
data from the clinical
       trials instead of stating your conclusion that the results were
successful.    Please also
       revise to explain whether your anecdotal evidence of the positive health
impact of your
       VINIA   health product can be used to help support a regulatory
approval. To the extent
       you intend to develop your products for medical indications, please
revise your
       Government Regulations section to disclose how pre-market approval and
       commercialization of pharmaceuticals is regulated in the jurisdictions
you intend to obtain
       such approval.
(c) Cosmeceuticals, page 25

5.     Please revise page 25 to disclose the number of participants in the skin
care assessment in
       Seoul, whether your products were used in the assessment, the skin
ailments assessed and
       the results data.
Principal Markets, page 26

6.     Please revise to include net income (loss) for the periods presented.
Item 5. Operating and Financial Review and Prospects, page 33

7.     We note your disclosure on page 26 indicating that over 90% of the sales
via your
       websites and call centers are subscription sales and that at least 95%
of these subscriptions
       are for periods equal to or greater than three months. We further note
your references to
       metrics that you have adopted such as cost of acquisition and lifetime
value. Please tell us
       and disclose if these subscription data and metrics constitute key
performance indicators
       that management uses to manage the business and that would be material
to investors. For
       guidance, refer to Staff Release 33-10751.
A. Operating Results
Research and Development Expenses, page 36

8.     We note your disclosure stating that your research and development
expenses increased
       during the fiscal year ended December 31, 2023 and during the three
months ended March
       31, 2024 as compared to the three months ended March 31, 2023 mainly due
to increases
       in wages, salaries, raw materials, depreciation, professional fees, and
share-based
       compensation. Please expand your disclosure to discuss the reasons for
the increases in
       your expenses to the extent they relate to the development of specific
products and
       services.
 July 10, 2024
Page 3

Item 6. Directors, Senior Management and Employees
C. Board Practices, page 49

9.     To the extent you are a foreign private issuer, please revise this
section, or elsewhere in
       the prospectus as appropriate, to disclose that you are a foreign
private issuer and to
       discuss the related implications for investors.
Item 7. Major Shareholders and Related Party Transactions
A. Major Shareholders, page 52

10.    Please revise to disclose the natural person(s) who have voting and/or
dispositive control
       over the common shares beneficially owned by Greensoil.
Item 10. Additional Information
C. Material Contracts, page 59

11.    Please revise your Material Contracts section to disclose the following:
           the identity of the other parties to the agreements;
           the aggregate amount paid to date pursuant to the Equipment
Agreement;
           the aggregate rent payments made pursuant to the Yavne No. 2
Agreement;
           the aggregate payments made to date and the term and termination
provisions of the
           License Agreement;
           aggregate payments made to date and the percentage of revenues from
first-time
           orders and subsequent orders to be paid pursuant to the TV Network
Agreement, or a
           range not exceeding 10 percentage points;
           the milestone metrics in the TV Network Agreement and the number of
Common
           Shares that could be issued if those metrics are achieved;
           the aggregate amounts received to date pursuant to the
Biopharmaceutical Partner
           Agreement and the Food Product Partner Agreement; and
           the aggregate payments made to date and the number of options issued
pursuant to the
           MZ Group Agreement.
 July 10, 2024
Page 4
Financial Statements for Fiscal Year Ended December 31, 2023
Note 12 - Convertible Loan, page F-31

12.    For each of your convertible loans A, B and C, please revise your
disclosure as follows:
           Disclose the actual principal amount of convertible loans issued
during each period,
           rather than just the "up to" amount authorized. To the extent that
issuances occurred
           in tranches, disclose the principal amount issued for each tranche,
the issuance date of
           each tranche and its maturity date.
           For each balance sheet date, disclose the difference between the
carrying amount and
           the amount you would be required to pay at maturity to the holder of
the obligation.
           Refer to paragraph 10(b) of IFRS 7.
           Provide additional disclosures to help reconcile your footnote
disclosure with the
           disclosure on page 79. In this regard, considering revising your
disclosure on page 79
           to present amounts outstanding in both Canadian and U.S. dollars and
indicate to
           which loans (A, B or C) the five remaining tranches relate.
Note 26- Subsequent Events, page F-46

13.    We note your disclosure stating that, on May 27, 2024, you approved a
35-for-1 share
       consolidation effective from June 3, 2024. Please revise all of the
share information your
       filing to give retroactive treatment to the reverse stock split,
including in your historical
       financial statements, in accordance with the guidance in SAB Topic 4C.
To the extent that
       this impacts the date(s) of your auditor's report, please have them
update accordingly.
Exhibits

14.    The consent from your auditor pertains to your financial statements as
of December 31,
       2023 and December 31, 2022 and for the years then ended, rather than for
the three years
       ended December 31, 2023. Please obtain a revised consent, and include it
with your next
       amendment.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Tracie Mariner at 202-551-3744 or Angela Connell at
202-551-3426 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Crawford at 202-551-7767 or Alan Campbell at 202-551-4224 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Steve O   Neill, Esq.
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