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United States securities and exchange commission logo





                           January 30, 2023

       David YL Leung
       Chief Executive Officer
       Euro Tech Holdings Company Limited
       Unit D, 18/F
       Gee Chang Hong Centre
       65 Wong Chuk Hang Road
       Hong Kong

                                                        Re: Euro Tech Holdings
Company Ltd.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Filed May 16, 2022
                                                            Amendment No. 1 to
Form 20-F for Fiscal Year Ended December 31, 2021
                                                            Filed September 23,
2022
                                                            Response filed
December 23, 2022
                                                            File No. 000-22113

       Dear David YL Leung:

               We have reviewed your December 23, 2022 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment 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 our
       comment applies to your facts and circumstances, please tell us why in
your response.

            After reviewing your response to this comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       November 17, 2022 letter.

       Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2021

       General

   1.                                                   We have reviewed your
responses to comments 5 and 6. Please file an amendment to
                                                        your Form 20-F, which
incorporates the revisions you agreed to make in response to these
                                                        comments.
 David YL Leung
Euro Tech Holdings Company Limited
January 30, 2023
Page 2

       You may contact Linda Cvrkel at (202) 551-3813 or Rufus Decker at (202)
551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at (202) 551-4515 or Lilyana Peyser at (202) 551-3222 with
any other
questions.



FirstName LastNameDavid YL Leung                          Sincerely,
Comapany NameEuro Tech Holdings Company Limited
                                                          Division of
Corporation Finance
January 30, 2023 Page 2                                   Office of Trade &
Services
FirstName LastName
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