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                                                                  March 11, 2009

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549-6010

Attn: Mr. Jim B. Rosenberg

     Re: China Pharma Holdings, Inc.
         Form  10-KSB for the Fiscal Year Ended December 31, 2007
         Forms 10-QSB for the Quarterly Periods Ended March 31 and June 30, 2008
         Form 10-Q for the Quarterly Period Ended September 30, 2008
         File No. 000-29523

Ladies and Gentlemen:

China Pharma  Holdings,  Inc.  (the  "Company")  received the Staff's  letter of
comment  dated  December 23, 2008 (the  "Comment  Letter") on February 28, 2009.
Below is our response to the Comment Letter.

Your comments have been set forth in italics and  paragraphs  have been numbered
to correspond to the numeration of the Comment Letter.

Concurrently  with this  response to the Comment  Letter,  the Company is filing
amendment  to Form  10-KSB for the  Fiscal  Year Ended  December  31,  2007 (the
"10-KSB/A"), and amendments to Forms 10-QSB and Form 10-Q for the 2008 quarterly
reports.

Form 10-KSB for the Fiscal Year Ended December 31, 2007
-------------------------------------------------------

PART I
------

Item 2. Description of Property, page 29
----------------------------------------

1.   We note that your subsidiary, Helpson, has entered into a lease with Hainan
     Zhongfu  Going-abroad  Personnel Service Center for its principal executive
     offices.  Please file this material  lease  agreement as an exhibit to your
     filing as required under Item 601(b)(10)(i)(D) of Regulation SB.

     In response to your comment,  the Company has filed the lease  agreement as
     exhibit 10.12 to Form 10KSB/A.

PART II
-------

Item 8A-Controls and Procedures, page 43
----------------------------------------

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2.   You  disclose  significant  deficiencies  in your  internal  controls  over
     financial  reporting  however it does not appear that you have  disclosed a
     definitive  conclusion of management's  assessment of the  effectiveness of
     internal  controls over financial  reporting.  Please revise your filing to
     include a statement  as to whether or not internal  control over  financial
     reporting is effective as required by Item 308T(a)(3) of Regulation S-B.

     Our  management  has  concluded  that the internal  control over  financial
     reporting was not effective.  In the second  paragraph under Item 8A of the
     Form  10-KSB/A,  it now reads that "our chief  executive  officer and chief
     financial  officer  concluded  that our internal  controls  over  financial
     reporting  and  procedures  were not  effective,  due to the  existence  of
     significant internal control deficiencies our disclosure...".

PART III
--------

Item 9. Directors, Executive Officers, Promoted, and Control Persons ...page 46
-------------------------------------------------------------------------------

Code of Ethics, page 48
-----------------------

3.   We note that you have not yet adopted a code of ethics.  Please  provide an
     explanation  for why you have not yet done so as required under Item 406(a)
     of Regulation SB.

     We have edited the disclosure in the 10KSB/A to explain that we have had an
     informal  Code of Ethics in our company,  but it had not be  formalized  in
     writing at that  time.  Please  note that we have  formalized  our  English
     version of our Code of Business Conduct and Ethics on July 8, 2008. You may
     refer to Exhibit 14.1 of Form S-1 filed on July 11, 2008.

Signatures, page 55
-------------------

4.   Please  provide  the  signature  of your  principal  accounting  officer or
     controller.  If one of the  individuals who have already signed your filing
     is also the principal  accounting  officer or controller,  please  indicate
     this  additional  capacity  in the  signature  block  appearing  below this
     individual's name.

     In response  to your  comment,  the  Company has made such  revision on the
     signature page of Form 10-KSB/A.

5.   We also note that only two of your directors have signed your filing.  Your


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     Form 10-KSB must be signed by at least majority of your board of directors.
     Please provide the signatures as required under General Instruction C(2) to
     Form 10-KSB.

     Our board of directors  was  comprised of three  members as of December 31,
     2007. The Form 10KSB was signed by a majority of the directors on the board
     as of that date. In addition, we have signatures of all five of our current
     directors on the 10KSB/A.

Exhibits 31- Certifications
---------------------------

6.   Please revise the wording of your certifications to be exactly as set forth
     in Item  601(b)(31) of Regulation  S-B. In this regard your  certifications
     include  the title of the officer and name of the company in the first line
     of the certification that identifies the certifying  officer.  This comment
     also applies to the certifications filed with your 2008 quarterly reports.

     In response  to your  comment,  the  Company has made such  revision on the
     certifications  filed  with  Form  10-KSB/A  and  amendments  to  our  2008
     quarterly reports.

Forms  10-QSB for the  Quarterly  Periods  Ended March 31 and June 30, 2008 Form
10-Q for the Quarterly Period Ended September 30, 2008

7.   It appears that you have not  disclosed the  conclusion  of your  Principal
     Executive   Officer  and   Principal   Financial   Officer   regarding  the
     effectiveness of your disclosure  controls and procedures as of end of each
     period covered by the reports as required under Item 307 of Regulation S-K.
     Please revise your filings to provide this disclosure.

     In response  to your  comment,  the  Company has made such  revision on the
     amendments to the 2008 quarterly reports.

The Company acknowledges that:

   (i) it is responsible  for the adequacy and accuracy of the disclosure in its
filings;

   (ii) staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to such filing;
and

   (iii)  the  Company  may  not  assert  staff  comments  as a  defense  in any
proceeding  initiated by the  Commission or any person under federal  securities
laws of the United States.


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If you have further requirements or questions, please do not hesitate to contact
the undersigned at (0086-898)-66811730  or by facsimile at  (0086-898)-66819024.
You may also contact our counsel, Charles Law of KING AND WOOD, LLP by facsimile
at (0086-10)-58785566.

                                     Very truly yours,

                                     By:  /s/ Zhilin Li
                                          -------------
                                          Zhilin Li
                                          President and CEO


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