<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                             February 16, 2024

       Wing Wah Cheng
       Chief Executive Officer
       Samfine Creation Holdings Group Limited
       Flat B, 8/F, Block 4
       Kwun Tong Industrial Centre
       436-446 Kwun Tong Road
       Kwun Tong, Kowloon
       Hong Kong

                                                        Re: Samfine Creation
Holdings Group Limited
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed February 8,
2024
                                                            File No. 333-275498

       Dear Wing Wah Cheng:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.

       Amendment No. 3 to Form F-1

       General

   1.                                                   We note the changes you
made to your disclosure appearing on the cover page, Summary,
                                                        and Risk Factor
sections relating to legal and operational risks associated with operating
                                                        in China and PRC
regulations. It is unclear to us that there have been changes in the
                                                        regulatory environment
in the PRC since the amendment that was filed on December
                                                        8, 2023, warranting
revised disclosure to mitigate the challenges you face and related
                                                        disclosures. The Sample
Letters to China-Based Companies sought specific disclosure
                                                        relating to the risk
that the PRC government may intervene in or influence your operations
                                                        at any time, or may
exert control over operations of your business, which could result in a
                                                        material change in your
operations and/or the value of the securities you are registering
 Wing Wah Cheng
Samfine Creation Holdings Group Limited
February 16, 2024
Page 2
      for sale. We remind you that, pursuant to federal securities rules, the
term    control
      (including the terms    controlling,       controlled by,    and    under
common control with   ) as
      defined in Securities Act Rule 405 means    the possession, direct or
indirect, of the power
      to direct or cause the direction of the management and policies of a
person, whether
      through the ownership of voting securities, by contract, or otherwise.
The Sample Letters
      also sought specific disclosures relating to uncertainties regarding the
enforcement of laws
      and that the rules and regulations in China can change quickly with
little advance
      notice. We do not believe that your revised disclosure referencing the
PRC government   s
      intent to strengthen its regulatory oversight conveys the same risk.
Please restore your
      disclosures in these areas to the disclosures as they existed in the
registration statement as
      of December 8, 2023.
Management
Compensation of Directors and Executive Officers, page 125

2.    Please update your compensation disclosure to reflect the fiscal year
ended December 31,
      2023.
       Please contact Beverly Singleton at 202-551-3328 or Hugh West at
202-551-3872 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Erin Purnell at 202-551-3454 with
any other
questions.



                                                             Sincerely,
FirstName LastNameWing Wah Cheng
                                                    Division of Corporation
Finance
Comapany NameSamfine Creation Holdings Group Limited
                                                    Office of Manufacturing
February 16, 2024 Page 2
cc:       Ying Li
FirstName LastName
</TEXT>
</DOCUMENT>
