September 6, 2018

Jianjun Xun
Chief Executive Officer
Organic Agricultural Company Limited
6th Floor A, Chuangxin Yilu
No. 2305, Technology Chuangxincheng
Gaoxin Jishu Chanye Technology Development District
Harbin City, Heilongjiang Province
China 150090

       Re: Organic Agricultural Company Limited
           Registration Statement on Form S-1
           Filed August 13, 2018
           File No. 333-226810

Dear Mr. Xun:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

Registration Statement on Form S-1

Cover Page

1.     We note that your calculation of registration fee table on your
registration statement cover
       page indicates that the proposed maximum price per share is $1.30 and
that
       your prospectus cover page indicates that the selling stockholders are
offering their shares
       of common stock at a fixed price of $2.00 per share. Please revise your
calculation of
       registration fee table for consistency and recalculate the proposed
maximum aggregate
 Jianjun Xun
FirstName LastNameJianjun Xun
Organic Agricultural Company Limited
Comapany 6, 2018
September NameOrganic Agricultural Company Limited
September 6, 2018 Page 2
Page 2
FirstName LastName
         offering price accordingly.
2.       We note your disclosure that the selling stockholders will offer and
sell common stock at a
         fixed price of $2.00 per share, "until a public market emerges" for
your common stock
         and, thereafter, at prevailing market prices. We also note your
disclosure on page 18 that
         you intend to apply for a listing on the Pink Market maintained by OTC
Markets, and then
         apply for a listing on the OTCQB as soon as you meet the standards for
such a listing.
         Please revise to disclose a fixed price at which shares will be sold
until your common
         stock is quoted on the OTCQB, at which time they may be sold at
prevailing market prices
         or in privately negotiated transactions. Refer to Item 501(b)(3) of
Regulation S-K.
Prospectus Summary, page 6

3.       We note your disclosure on page 6 that the supplemental agreement gave
Hao Shuping
         control over Lvxin and its business, including personnel management,
management of
         sales, purchases and accounting. We also note your disclosure that Hao
Shuping
         subsequently transferred all of his 51% equity interest in Lvxin to
Tianci Liangtian.
         Please revise to clarify whether the supplemental agreement continues
to give Hao
         Shuping control over Lvxin.
Risk Factors
Risks Related to Our Business
If our estimates related to future expenditures are erroneous, page 11

4.       We note your disclosure that your "success is dependent in part upon
the accuracy of
         [your] management's estimates of [your] future cost expenditures for
land acquisition,
         legal and accounting services . . . , for research and development,
marketing, and for
         administrative expenses." Please disclose the estimated amount of
capital required for the
         next twelve months to accomplish your planned business goals.
Business of the Company, page 23

5.       We note your disclosure on page 5 that Yuxinqi has not yet initiated
operations. If
         known, please disclose when Yuxinqi will begin operations.
Operating Licenses, page 27

6.       We note that your licenses are valid "for long-term use." Please
provide a definition for
         "long-term use" that includes quantitative information.
Farmland Leases, page 28

7.       We note your disclosure that you are a party to approximately 300
leases for an aggregate
         of 497 hectares. Please disclose any material terms of the leases.
 Jianjun Xun
Organic Agricultural Company Limited
September 6, 2018
Page 3

        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.

       You may contact Melissa Gilmore at 202-551-3777 or Jean Yu, Assistant
Chief
Accountant, at 202-551-3305 if you have questions regarding comments on the
financial
statements and related matters. Please contact Sonia Bednarowski at
202-551-3666 or Laura
Nicholson, Special Counsel, at 202-551-3584 with any other questions.



FirstName LastNameJianjun Xun                              Sincerely,
Comapany NameOrganic Agricultural Company Limited
                                                           Division of
Corporation Finance
September 6, 2018 Page 3                                   Office of
Transportation and Leisure
FirstName LastName