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                                                            March 5, 2025

Jennifer Zhan
Chief Executive Officer
Shineco, Inc.
Room 1707, Block D, Modern City SOHO,
No. 88, Jianguo Road, Chaoyang District,
Beijing, People   s Republic of China 100022

       Re: Shineco, Inc.
           Registration Statement on Form S-1
           Filed February 18, 2025
           File No. 333-285025
Dear Jennifer Zhan:

       We have conducted a limited review of your registration statement and
have the
following comment.

        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.

Registration Statement on Form S-1
General

1.     We note various references to the opinion of Shineco's PRC legal
counsel, Beijing
       Yingke Law Firm, throughout the registration statement. For example, we
note your
       disclosure on page 7 that "[i]n the opinion of [y]our PRC legal counsel,
Beijing
       Yingke Law Firm, as this offering does not constitute a subsequent
offering by [you],
       [you] are not required to file with the CSRC in accordance with the
Trial Measures in
       connection with this offering", and your disclosure on page 25 that
"[a]s confirmed by
       [y]our PRC counsel, Beijing Yingke Law Firm...[you] will not be subject
to
       cybersecurity review by the CAC under the Cybersecurity Review Measures,
nor will
       any such entity be subject to the Security Administration." Please
revise to file the
       opinion of your PRC counsel.
 March 5, 2025
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Juan Grana at 202-551-6034 or Katherine Bagley at
202-551-2545
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Ying Li, Esq.
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