July 31, 2019

Yin Yan
Chief Executive Officer
Bio Essence Corp.
8 Studebaker Drive
Irvine, CA 92618

       Re: Bio Essence Corp.
           Registration Statement on Form S-1
           Filed July 26, 2019
           File No. 333-232839

Dear Mr. Yan:

        We have the following comment. Please respond to this letter by
amending your
registration statement. If you do not believe our 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, we may
have additional
comments.

Registration Statement on Form S-1

General

1.    We note that the financial statements included in the registration
statement are as of a date
      135 days or more before the date the document was filed. As such, we will
not perform a
      detailed examination of the registration statement until you amend your
registration
      statement to update the financial statements in compliance with Rule 8-08
of Regulation
      S-X. Assuming that you amend your registration statement before August
13th, include
      the interim financial statements for the the three months ended March 31,
2019 and the
      comparable prior year period. Since this interim financial information
will be included in
      a historical period that will be required to be included in this
registration statement at the
      time of the contemplated offering, it may not be omitted from your filed
registration
      statement. Update the associated financial information in applicable
sections of the filing
      as appropriate such as the MD&A section. For guidance, please refer to
Question 1 of the
      Fixing America's Surface Transportation (FAST) Act Compliance and
Disclosure
      Interpretations, available on the Commission's website.

       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
 Yin Yan
Bio Essence Corp.
July 31, 2019
Page 2

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 Jim Rosenberg at 202-551-3679 if you have questions
regarding
comments on the financial statements and related matters. Please contact Ada D.
Sarmento at
202-551-3798 or Mary Beth Breslin at 202-551-3625 with any other questions.



FirstName LastNameYin Yan                                  Sincerely,
Comapany NameBio Essence Corp.
                                                           Division of
Corporation Finance
July 31, 2019 Page 2                                       Office of Healthcare
& Insurance
FirstName LastName